Farmers Ins. Exchange et al v. PacifiCorp
Filing
35
STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr on 7/14/2021 DIRECTING the parties to meet and confer within 21 days of the court's order resolving the Motion to Remand if the court retains jurisdiction and to submit their proposed discovery plan and initial disclosures within 14 days of their discovery conference pursuant to Local Rule 240(b). (Coll, A)
1 HUESTON HENNIGAN LLP
Douglas J. Dixon, State Bar No. 275389
2 ddixon@hueston.com
Derek R. Flores, State Bar No. 304499
3 dflores@hueston.com
4 620 Newport Center Drive, Suite 1300
Newport Beach, CA 92660
(949) 229-8640
5 Telephone:
Facsimile:
(888) 775-0898
6
Attorneys for Defendant PacifiCorp
7
8
BERGER KAHN, A Law Corporation
Craig S. Simon, State Bar No. 78158
csimon@bergerkahn.com
Bonnie J. Bennett, State Bar No. 240313
bbennett@bergerkahn.com
Christine Forsline, State Bar No. 333451
cforsline@bergerkahn.com
1 Park Plaza, Suite 340
Irvine, CA 92614
Telephone:
(949) 474-1880
Facsimile:
(949) 313-51029
Attorneys for Plaintiffs Farmers Insurance
Exchange, et al.
9
UNITED STATES DISTRICT COURT
10
EASTERN DISTRICT OF CALIFORNIA
11 FARMERS INSURANCE EXCHANGE, et al., Case No. 2:21-cv-00801-MCE-CKD
Plaintiffs,
12
JOINT STIPULATION REGARDING
DISCOVERY PLAN
vs.
13
[Related Case No.: 2:21-cv-00848-MCE-CKD]
14 PacifiCorp, et al.,
Defendants.
15
16
After meeting and conferring pursuant to the Court’s Initial Pretrial Scheduling Order (Dkt.
17
18 No. 4), Plaintiffs Farmers Insurance Exchange et al. and Defendant PacifiCorp (together, the
19 Parties) jointly submit the following stipulation regarding the parties’ obligations to submit a
20 discovery plan and initial disclosures pursuant to Federal Rule of Civil Procedure 26(f) and Local
21 Rule 240.
WHEREAS Plaintiffs have moved to remand this case to Sacramento Superior Court, and
22
23 Defendant has opposed that motion and moved to strike Plaintiffs’ reply brief or for leave to file a
24 surreply, and both motions remain pending before the Court;
WHEREAS the Parties have each moved to amend their respective initial pleadings, and
25
26 both motions remain pending before the Court;
27
28
-1-
JOINT STIPULATION REGARDING DISCOVERY PLAN
6004730
WHEREAS the Parties mutually desire to avoid the time and expense necessary to prepare
1
2 a discovery plan, initial disclosures, or otherwise to begin conducting discovery in federal court in
3 light of the pending motions;
WHEREAS this case is related to another pending case, Hillman et al. v. PacifiCorp et al.,
4
5 No. 2:21-cv-00848-MCE-CKD, and also relates to a pending state court action, Hitchcock et al. v.
6 PacifiCorp et al., No. 34-2020-00290833, and the parties desire to informally coordinate discovery
7 between the three cases to reduce costs to all parties and streamline the discovery process;
WHEREAS the present stipulation does not constitute an admission by either party that this
8
9 case will or should remain in federal court, nor an admission that this case will or should be
10 remanded, respectively, nor on any other issue, and both Parties reserve all rights;
11
NOW, THEREFORE, subject to the Court’s approval, the Parties stipulate as follows:
12
1. If the Court retains jurisdiction, the Parties shall meet and confer regarding a discovery
13
plan within twenty-one (21) days of the Court’s order resolving the motion to remand;
14
2. The Parties shall submit their proposed discovery plan and initial disclosures within
fourteen (14) days of their discovery conference pursuant to Local Rule 240(b).
15
16
17
Dated: July 9, 2021
18
BERGER KAHN
By:
19
20
21
Dated: July 9, 2021
22
23
25
26
27
HUESTON HENNIGAN LLP
By:
24
Craig Simon
Attorneys for Plaintiffs Farmers Insurance
Exchange, et al.
Douglas J. Dixon
Derek R. Flores
Attorneys for Defendant PacifiCorp
IT IS SO ORDERED.
28 Dated: July 14, 2021
-2-
JOINT STIPULATION REGARDING DISCOVERY PLAN
6004730
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