Jaradah et al v. AMCO Ins. Co.

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)

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: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiffs
MARWAN JARADAH, ZIAD MUBARAKA, and ASEF
KASSIH

8
9
DENTONS US LLP
1999 HARRISON STREET, SUITE 1300
OAKLAND, CALIFORNIA 94612-4709
[phone]

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: [phone]
Facsimile: [phone]
E-mail: [e-mail]
[e-mail]

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
[phone]

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
[phone]

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
[phone]

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
[phone]

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