JJC Foods, Inc. et al v. Nationwide Mutual Insurance Company

Filing 17

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 1/7/2021 REVISING 11 Status (Pretrial Scheduling) Order as follows: Designation of Expert Witnesses due by 6/1/2021, Expert Discovery Cut-Off: 7/6/2021, Completion of All Discovery d ue 8/2/2021, Discovery Motion Hearing Cut-Off: 8/2/2021, Dispositive Pre-Trial Motion Hearing Cut-Off: 9/10/2021, Final Pretrial Conference set for 12/6/2021 at 01:30 PM in Courtroom 5 (WBS) before Senior Judge William B. Shubb, and Trial set for 2/8/2022 at 09:00 AM in Courtroom 5 (WBS) before Senior Judge William B. Shubb. (Huang, H)

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Richard D. Carter (SBN 125523)
Eugene P. Sands (SBN 171504)
CARTER SANDS, LLP
24025 Park Sorrento, Suite 280
Calabasas, California 91302
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]
Attorneys for Plaintiffs
JJC FOODS, INC., and JOHN CLIFFORD

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DENTONS US LLP
ONE MARKET PLAZA, SPEAR TOWER, 24TH FLOOR
SAN FRANCISCO, CA 94105
[phone]

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SONIA MARTIN (SBN 191148)
MENGMENG ZHANG (SBN 280411)
DENTONS US LLP
One Market Plaza, Spear Tower, 24th Floor
San Francisco, California 94105
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]
Attorneys for Defendant
NATIONWIDE MUTUAL INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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JJC FOODS, INC., a California Corporation
dba The Depot and Culinary Creations;
JOHN CLIFFORD, an individual,

Case No. 2:19-cv-02384-WBS-DMC
STIPULATION AND ORDER TO
CONTINUE TRIAL DATE AND FINAL
PRETRIAL CONFERENCE

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Plaintiffs,
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vs.
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Action Filed: September 26, 2019
NATIONWIDE MUTUAL INSURANCE
COMPANY, an Ohio Corporation, and
DOES 1 through 5, inclusive,

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Defendants.
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Plaintiffs JJC Foods, Inc. and John Clifford and defendant Nationwide Mutual Insurance
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Company (collectively, the “Parties”), by and through their respective counsel of record, hereby

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stipulate and agree as follows, and respectfully request the Court approve their stipulation for
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good cause shown:
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-1CASE NO. 2:19-CV-02384-WBS-DMC

FURTHER STIPULATION AND ORDER TO CONTINUE
TRIAL DATE AND PRETRIAL DEADLINES

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WHEREAS, on June 19, 2020, this Court granted the Parties’ stipulated request (Dkt. No.
13) to continue the final pretrial conference to August 2, 2021 and trial to October 5, 2021.
WHEREAS, the Parties are engaged in productive settlement negotiations and wish to

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continue exploring settlement without incurring litigation costs associated with a summary

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judgment motion that may be unnecessary;

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WHEREAS, the Parties request a continuance of the current trial date to February 8, 2022

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and a continuance of the current final pretrial conference to December 6, 2021, or to subsequent

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dates convenient to the Court’s calendar, and request a concurrent continuance of all motion

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deadlines (including but not limited to dispositive motion deadlines) and nonexpert and expert

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discovery deadlines;
WHEREAS, the Parties stipulate and request the Court enter the following revised Status
(Pretrial Scheduling) Order:

DENTONS US LLP
ONE MARKET PLAZA, SPEAR TOWER, 24TH FLOOR
SAN FRANCISCO, CA 94105
[phone]

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Designation of Expert Witnesses

June 1, 2021

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Expert Discovery Cut-Off:

July 6, 2021

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Completion of All Discovery

August 2, 2021

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Discovery Motion Hearing Cut-Off

August 2, 2021

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Dispositive Pre-Trial Motion Hearing Cut-Off:

September 10, 2021

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Final Pretrial Conference:

December 6, 2021

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Trial:

February 8, 2022

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WHEREAS, the requested trial and final pretrial conference dates have been cleared with

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the Court’s calendar.
IT IS SO STIPULATED.

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-2CASE NO. 2:19-CV-02384-WBS-DMC

STIPULATION AND ORDER TO
CONTINUE TRIAL DATE AND PRETRIAL
DEADLINES

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Dated: January 6, 2021

CARTER SANDS, LLP

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By (As Approved On 1/06/2021)
/s/ RICHARD D. CARTER_____________
RICHARD D. CARTER
EUGENE P. SANDS
Attorneys for Plaintiffs
JJC FOODS, INC., and JOHN CLIFFORD

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Dated: January 6, 2021

DENTONS US LLP

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By: /s/ SONIA MARTIN
SONIA MARTIN
MENGMENG ZHANG
Attorneys for Defendant
NATIONWIDE MUTUAL INSURANCE
COMPANY

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DENTONS US LLP
ONE MARKET PLAZA, SPEAR TOWER, 24TH FLOOR
SAN FRANCISCO, CA 94105
[phone]

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IT IS SO ORDERED.
Dated: January 7, 2021

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-3CASE NO. 2:19-CV-02384-WBS-DMC

STIPULATION AND ORDER TO
CONTINUE TRIAL DATE AND PRETRIAL
DEADLINES