Jeff & Amy, Inc et al v. Safeco Insurance Company of America

Filing 32

STIPULATION AND ORDER AMENDING CERTAIN DATES SET FORTH IN THE JULY 25, 2012 CASE MANAGEMENT ORDER re 31 STIPULATION WITH PROPOSED ORDER. Signed by Judge Jon S. Tigar on April 1, 2013. (wsn, COURT STAFF) (Filed on 4/1/2013)

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SEDGWICK LLP
BRUCE D. CELEBREZZE, SBN 102181
[e-mail]
NICHOLAS J. BOOS, SBN 233399
[e-mail]
JASON J. CHORLEY, SBN 263225
[e-mail]
333 Bush Street, 30th Floor
San Francisco, California 94104
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
AMERICAN ECONOMY INSURANCE COMPANY

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LAW OFFICE OF BRIAN K. VARGHESE
BRIAN K. VARGHESE (SBN 262664)
84 West Santa Clara Street, Suite 540
San Jose, California 95113
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorney for Plaintiff
JEFF & AMY, INC.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JEFF & AMY, INC., et al.,

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Plaintiffs,
v.
AMERICAN ECONOMY INSURANCE
COMPANY, an Indiana corporation, and DOES
ONE through TWENTY inclusive.

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Case No. 3:12-cv-02075-JST
STIPULATION AND [PROPOSED]
ORDER AMENDING CERTAIN
DATES SET FORTH IN THE JULY 25,
2012 CASE MANAGEMENT ORDER
[ECF NO. 21]

Defendants.

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-1STIPULATION AND [PROPOSED] ORDER AMENDING CERTAIN DATES SET FORTH IN THE JULY 25,
2012 CASE MANAGEMENT ORDER

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Plaintiff JEFF & AMY, INC. (“Jeff & Amy”), and defendant AMERICAN ECONOMY

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INSURANCE COMPANY (“AEIC”), erroneously sued as Safeco Insurance Company of America

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(collectively the “Parties”), by and through their respective counsel, and subject to the Court’s

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order, hereby stipulate and agree as follows:

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WHERAS, on or about July 25, 2012 this Court issued a Case Management Order (ECF
No. 21) setting forth the following schedule, in part, for this matter:

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Completion of Fact Discovery:

[4/5/13]

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Disclosure of identities and reports of expert witnesses:
Supplemental:

[4/12/13]
[5/10/13]

Completion of Expert Discovery:

[5/31/13]

All case-dispositive motions to be heard at 2:00 P.M. on or before:

[6/20/13]

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WHEREAS, on or about February 12, 2013, this Court issued a Reassignment Order (ECF
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No. 25) maintaining the fact and expert discovery deadlines, and vacating the pretrial conference
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and trial dates;
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WHEREAS, the primary dispute between the Parties pertains to Jeff & Amy’s business
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income loss claim;
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WHEREAS, following the issuance of the March 4, 2013 Stipulated Protective Order, Jeff
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& Amy produced additional documents – which it contends are confidential – that it contends
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support its business income loss claim;
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WHEREAS, the Parties have agreed to continue discussions regarding the possible
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informal resolution of this action, and have agreed to engage in those further discussions before
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incurring the expense associated with depositions;
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WHEREAS, considerations of efficiency and judicial economy support extending the
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deadline to complete discovery in order to facilitate discussions between the Parties regarding a
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possible informal resolution;
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WHEREAS, the Parties wish to extend only the discovery and motion deadlines.
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IT IS HEREBY STIPULATED by and between Jeff & Amy and AEIC that the schedule
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set forth in the Court’s July 25, 2012 Case Management Order (ECF No. 21) be amended as
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-2STIPULATION AND [PROPOSED] ORDER AMENDING CERTAIN DATES SET FORTH IN THE JULY 25,
2012 CASE MANAGEMENT ORDER

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follows:

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Completion of Fact Discovery:

[5/31/13]

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Disclosure of identities and reports of expert witnesses:
Supplemental:

[6/7/13]
[7/5/13]

Completion of Expert Discovery:

[7/26/13]

All case-dispositive motions to be heard at 2:00 P.M. on or before:

[8/15/13]

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DATED: March 28, 2013

LAW OFFICE OF BRIAN K. VARGHESE

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By: /s/ Brian K. Varghese
Brian K. Varghese, Esq.
Attorney for Plaintiff
JEFF & AMY, INC.

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DATED: March 28, 2013

SEDGWICK LLP

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By: /s/ Jason J. Chorley
Bruce D. Celebrezze
Nicholas J. Boos
Jason J. Chorley
Attorneys for Defendant
AMERICAN ECONOMY INSURANCE
COMPANY

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April 1, 2013
DATED:_________________

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ED
_____________________________________
ORDER
IS SO S. TIGAR
IT
HON. JON

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UNIT
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. Ti ga r

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ISTRIC
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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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-3STIPULATION AND [PROPOSED] ORDER AMENDING CERTAIN DATES SET FORTH IN THE JULY 25,
2012 CASE MANAGEMENT ORDER

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