Jaradah et al v. AMCO Insurance Company

Filing 11

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr on 9/15/22 ORDERING that Non-Expert Discovery cut-off: 2/23/2023. Designation of Expert Witnesses: 4/24/2023. Designation of Rebuttal Experts: 5/24/2023. Discovery Motion Hearing cut-off: 8/22/2023. Joint Notice of Trial Readiness: 30 Days After Ruling on Dispositive Motions. (Kaminski, H)

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1 2 3 4 5 6 7 LIA MICHELLE JUHL-RHODES (SB No 268816) PETERS, HABIB, McKENNA, JUHL-RHODES & CARDOZA, LLP P.O. Box 3509 414 Salem Street Chico, CA 95928 Telephone: (530) 342-3593 Facsimile: (530) 342-4242 E-Mail: ljuhl@peterslawchico.com Attorneys for Plaintiffs MARWAN JARADAH, ZIAD MUBARAKA, and ASEF KASSIH 8 9 DENTONS US LLP 1999 HARRISON STREET, SUITE 1300 OAKLAND, CALIFORNIA 94612-4709 (415) 882-5000 10 11 12 SONIA MARTIN (State Bar No. 191148) EMILY NOZICK (State Bar No. 201050) DENTONS US LLP 1999 Harrison Street, Suite 1300 Oakland, California 94612 Telephone: (415) 267-4000 Facsimile: (415) 267-4198 E-mail: sonia.martin@dentons.com emily.nozick@dentons.com 13 14 Attorneys for Defendants AMCO INSURANCE COMPANY aka NATIONWIDE INSURANCE COMPANY 15 16 17 UNITED STATES DISTRICT COURT 18 EASTERN DISTRICT OF CALIFORNIA 19 20 21 MARWAN JARADAH, an individual, ZIAD MUBARAKA, an individual, ASEF KASSIH, an individual, 24 25 26 27 STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINE 90 DAYS Plaintiffs, 22 23 Case No. 2:21-CV-02179-MCE-DMC vs. AMCO INSURANCE COMPANY aka NATIONWIDE INSURANCE COMPANY, an Ohio Corporation doing business in California; and DOES 1 to 30, inclusive, Defendants. 28 Case No. 2:21-CV-02179-MCE-DMC US_ACTIVE\122271366\V-1 -1- STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINE 90 DAYS 1 Plaintiffs Marwan Jaradah, Ziad Mubaraka, Asef Kassih and defendant AMCO Insurance 2 Company aka Nationwide Insurance Company, by and through their respective counsel of 3 record, stipulate and agree as follows and respectfully request entry of an order giving effect to 4 their stipulation: 5 6 No. 1); 7 WHEREAS, pursuant to the Initial Pretrial Scheduling Order, all discovery, with the 8 exception of expert discovery, shall be completed no later than 365 days from the date upon 9 which the last answer may be filed, or from the date of removal, whichever is later (see ECF Dkt. 10 DENTONS US LLP 1999 HARRISON STREET, SUITE 1300 OAKLAND, CALIFORNIA 94612-4709 (415) 882-5000 WHEREAS, AMCO filed a Notice of Removal on November 23, 2021 (see ECF Dkt. 11 No. 3); WHEREAS, the parties have engaged in written discovery during this period, but, due to 12 scheduling conflicts, and unavailability of witnesses, and parties being out of the country for a 13 majority of the summer, have been unable to schedule the requisite depositions; 14 WHEREAS, the Court has not previously modified any deadlines in this case; 15 WHEREAS, a continuance of the discovery deadline and, as a result, other case deadlines 16 is necessary to provide the parties with adequate time to explore potential case resolution and to 17 avoid unproductive proceedings and unnecessary litigation costs; 18 WHEREAS, the parties agree that the interests of judicial economy, efficiency and 19 convenience of the Court and the parties would be furthered by continuing the dates in the Initial 20 Pretrial Scheduling Order (ECF Dkt. No. 3) by 90 days, as follows: 21 Original Deadline 22 Proposed Deadline (Adding 90 Days) 23 Non-Expert Discovery 24 Cut-Off 25 Designation of Expert 26 Witnesses November 23, 2022 February 23, 2023 January 23, 2023 April 24, 2023 27 28 Case No. 2:21-CV-02179-MCE-DMC US_ACTIVE\122271366\V-1 -2- STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINE 90 DAYS 1 2 3 4 5 6 Designation of Rebuttal February 22, 2023 May 24, 2023 May 22, 2023 August 22, 2023 Joint Notice of Trial 30 Days After Ruling on 30 Days After Ruling on Readiness Dispositive Motions Dispositive Motions Experts Discovery Motion Filing Cut-Off 7 WHEREAS, the parties agree that all other case deadlines, including trial and motion 8 deadlines, and dates imposed by order, local rules, or otherwise, shall be reset in accordance with 9 the 90 day continuance requested; DENTONS US LLP 1999 HARRISON STREET, SUITE 1300 OAKLAND, CALIFORNIA 94612-4709 (415) 882-5000 10 NOW, THEREFORE, IT IS AGREED AND STIPULATED that: 11 The deadlines in this matter, set forth in the Initial Pretrial Scheduling Order and all other 12 case deadlines be continued by 90 days as set forth in part in the table above, or as soon 13 thereafter as the Court’s calendar allows. Alternatively, the parties respectfully request that the 14 Court set a further case management conference at which new dates may be selected. 15 The parties respectfully request the Court to adopt the foregoing stipulation as the order 16 of the Court. 17 IT IS SO STIPULATED. 18 19 Dated: September 9, 2022 20 PETERS, HABIB, McKENNA, JUHL-RHODES & CARDOZA, LLP 21 By: 22 23 /s/ Lia Michelle Juhl-Rhodes LIA MICHELLE JUHL-RHODES Attorney for Plaintiffs MARWAN JARADAH, ZIAD MUBARAKA, and ASEF KASSIH 24 25 26 27 28 Case No. 2:21-CV-02179-MCE-DMC US_ACTIVE\122271366\V-1 -3- STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINE 90 DAYS 1 Dated: September 9, 2022 DENTONS US LLP 2 3 By: 4 5 /s/ Emily Nozick SONIA MARTIN EMILY NOZICK Attorneys for Defendants AMCO INSURANCE COMPANY, aka NATIONWIDE INSURANCE COMPANY 6 7 8 9 DENTONS US LLP 1999 HARRISON STREET, SUITE 1300 OAKLAND, CALIFORNIA 94612-4709 (415) 882-5000 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case No. 2:21-CV-02179-MCE-DMC US_ACTIVE\122271366\V-1 -4- STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINE 90 DAYS 1 DENTONS US LLP 1999 HARRISON STREET, SUITE 1300 OAKLAND, CALIFORNIA 94612-4709 (415) 882-5000 2 ORDER Pursuant to the above stipulation, the Court hereby continues the deadlines set forth in the 3 Court’s Initial Pretrial Scheduling Order and all other case deadlines by 90 days, in part, as 4 follows: 5 Non-Expert Discovery Cut- 6 Off 7 Designation of Expert 8 Witnesses 9 Designation of Rebuttal February 23, 2023 April 24, 2023 May 24, 2023 10 Experts 11 Discovery Motion Hearing 12 Cut-Off 13 Joint Notice of Trial 30 Days After Ruling on 14 Readiness Dispositive Motions August 22, 2023 15 16 IT IS SO ORDERED. 17 18 Dated: September 15, 2022 19 20 21 22 23 24 25 26 27 28 Case No. 2:21-CV-02179-MCE-DMC US_ACTIVE\122271366\V-1 -5- STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINE 90 DAYS

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