Golden Opportunity Investments, LP et al v. Falls Lake National Ins. Co.

Filing 11

STIPULATION and ORDER signed by District Judge Troy L. Nunley on 11/18/21 EXTENDING the non-expert discovery cutoff to 2/7/22. (Kastilahn, A)

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RANDY M. HESS (SBN 88635)
[e-mail]
PAMELA A. BOWER (SBN 151701)
[e-mail]
HESS BOWER ADAMS-HESS, PC
2105 S. Bascom Avenue, Suite 200
Campbell, CA 95008
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Plaintiffs
GOLDEN OPPORTUNITY INVESTMENTS, LP;
PAMA MANAGEMENT, INC.
MARIA S. QUINTERO (SBN 223629)
[e-mail]
TRAVIS WALL (SBN 191662)
[e-mail]
HINSHAW & CULBERTSON LLP
One California Street, 18th Floor
San Francisco, CA 94111
Telephone:
415-362-6000
Facsimile:
415-834-9070
Attorneys for Defendant
FALLS LAKE NATIONAL INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

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GOLDEN OPPORTUNITY INVESTMENTS, )
LP; AND PAMA MANAGEMENT, INC.,
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Plaintiffs,
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vs.
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FALLS LAKE NATIONAL INSURANCE
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COMPANY and DOES 1 to 50, inclusive,
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Defendants.
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Case No. 2:21-cv-00511-TLN-KJN
STIPULATION AND ORDER
EXTENDING DISCOVERY CUTOFF
Complaint Filed: November 19, 2020

IT IS HEREBY STIPULATED BY AND BETWEEN THE PARTIES TO THIS ACTION,
through their undersigned counsel, as follows:
1.

Pursuant to the timelines established by this Court’s Initial Pretrial Scheduling Order,

adopted by the parties in their Joint Rule 26(f) Discovery Plan, the last date for completion of non1

STIPULATION AND ORDER EXTENDING DISCOVERY CUTOFF
Case No. 2:21-cv-00511-TLN-KJN

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expert discovery is November 22, 2021.
2.

Good cause exists for the extension of the current non-expert discovery cutoff. The

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parties desire to proceed to voluntary mediation in this matter. They have agreed to mediate before

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Michael Ornstil, Esq., of JAMS on November 30, 2021. In order to facilitate mediation, the parties

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wish to direct time and resources toward mediation and agree to extend the time to complete non-

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expert discovery until after the initial mediation and any followup mediation discussions have

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concluded.

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3.

The parties stipulate and agree to extend the non-expert discovery cutoff for a period

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of approximately 75 days from November 22, 2021 through and including February 7, 2022. (Note

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that 75 days ends on Saturday, February 5, 2022, so we have extended the deadline out to the following

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Monday, February 7, 2022.)

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4.

This stipulated extension would allow the parties to conclude mediation and, if the

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matter does not resolve, complete outstanding discovery in sufficient time to commence expert

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discovery within the scheduled deadlines. This extension should not interfere with any other deadlines

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or hearings currently set. This extension also accounts for the unavailability of counsel and witnesses

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during the intervening holidays.

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5.

Based on the foregoing, the parties hereby stipulate to extend the non-expert discovery

cutoff from November 22, 2021 through and including February 7, 2022.
IT IS SO STIPULATED.
Dated: November 18, 2021

HESS BOWER ADAMS-HESS, PC
By: /s/ Pamela Bower
RANDY M. HESS
PAMELA A. BOWER
Attorneys for Plaintiffs
GOLDEN OPPORTUNITY INVESTMENTS,
LP and PAMA MANAGEMENT, INC.

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STIPULATION AND ORDER EXTENDING DISCOVERY CUTOFF
Case No. 2:21-cv-00511-TLN-KJN

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Dated: November 18, 2021

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HINSHAW & CULBERTSON LLP
By: /s/ Travis Wall
MARIA S. QUINTERO
TRAVIS WALL
Attorneys for Defendant
FALLS LAKE NATIONAL INSURANCE
COMPANY

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ORDER

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The Court having reviewed the foregoing stipulation of the parties, and good cause appearing
therefor, hereby orders as follows:
The non-expert discovery cutoff shall be and hereby is extended through and including
February 7, 2022.
IT IS SO ORDERED.
Dated: November 18, 2021

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Troy L. Nunley
United States District Judge

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STIPULATION AND ORDER EXTENDING DISCOVERY CUTOFF
Case No. 2:21-cv-00511-TLN-KJN

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FILER’S ATTESTATION

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I, Pamela Bower, am the ECF user whose identification and password are being used to file

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this STIPULATION AND PROPOSED ORDER EXTENDING DISCOVERY CUTOFF. In

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compliance with Local Rules, I hereby attest that all party signatories hereto concur in this filing.

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/s/ Pamela Bower
PAMELA BOWER

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STIPULATION AND ORDER EXTENDING DISCOVERY CUTOFF
Case No. 2:21-cv-00511-TLN-KJN