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)

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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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