St. Paul Fire and Marine Insurance Company v. Admiral Insurance Company et al

Filing 106

STIPULATION AND ORDER re 105 STIPULATION WITH PROPOSED ORDER re 87 SCHEDULING ORDER filed by St. Paul Fire and Marine Insurance Company. Signed by Judge Jon S. Tigar on January 17, 2014. (wsn, COURT STAFF) (Filed on 1/17/2014)

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THE AGUILERA LAW GROUP, APLC
A. Eric Aguilera (SBN 192019)
Kimberly R. Arnal (SBN 200448)
650 Town Center Drive, Suite 100
Costa Mesa, CA 92626
[e-mail]
[e-mail]
T: 714.384.6600 / F: 714.384.6601

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Attorneys for Plaintiffs ST. PAUL FIRE AND MARINE INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO DIVISION

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ST. PAUL FIRE AND MARINE
INSURANCE COMPANY, a Minnesota
corporation

Case No. 3:12-cv-04160-JST
Honorable Jon S. Tigar – Courtroom
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Plaintiff,

STIPULATION TO AMEND CASE
MANAGEMENT ORDER AND
CONTINUE CERTAIN DATES

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v.

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ADMIRAL INSURANCE COMPANY,
a Delaware corporation, et al.,
Defendants.

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WHEREAS, several of the parties to this action are actively participating in
settlement discussions;
WHEREAS, the parties believe that continuing the dates for the remaining
permissible fact discovery by 40 days will facilitate settlement discussions;
WHERAS, continuing the discovery fact cut-off date necessitates the continuing
certain other dates;

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WHEREAS, on November 20, 2013, the trial court in the Underlying Action

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entitled STRS Ohio CA Real Estate Investment I, LLC v. ACCO Engineering Systems,
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Case No. 3:12-cv-04160-RS

STIPULATION TO AMEND CASE MANAGEMENT ORDER

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Inc., et al., Alameda Superior Court Case Number RG10-496973 (“Underlying

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Action”) continued the trial date of that action to February 3, 2014.

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WHEREAS, the parties to the Underlying Action continue to take expert

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depositions up to and including this week and the parties to the instant action

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anticipate that discovery in the Underlying Action will be relevant to resolution of

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this matter, the Parties request that the Court modify the Scheduling Order and

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continue the fact discovery deadline by 40-day.

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IT IS HEREBY STIPULATED by and between St. Paul and Defendants

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who remain in this action, by and through their designated counsel, and subject to the

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approval of this Court, to amend the Case Management Order as follows:

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EVENT

DEADLINE

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Fact discovery cut-off

3/14/14

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Expert disclosures

3/28/14

Expert rebuttal

4/11/14

Expert discovery cut-off

5/2/14

Deadline for Filing Dispositive Motions

5/23/14

Pretrial conference statement due

7/8/14

Pretrial conference

7/18/14 at 2:00 pm

Trial

8/4/14 at 8:30 am

Estimate of trial length (in days)

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Dated: January 17, 2014 THE AGUILERA LAW GROUP, APLC
/s/ Kimberly R. Arnal
A. Eric Aguilera
Kimberly R. Arnal
Attorneys for Plaintiff ST. PAUL FIRE AND
MARINE INSURANCE COMPANY
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Case No. 3:12-cv-04160-RS

STIPULATION TO AMEND CASE MANAGEMENT ORDER

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Dated: January 17, 2014

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BOORNAZIAN, JENSEN & GARTHE
___/s/ Alan E. Swerdlow_________________
Alan E. Swerdlow
Attorneys for Defendant AMERICAN SAFETY
INDEMNITY COMPANY

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Dated: January 17, 2014

SELVIN WRAITH HALMAN LLP

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__/s/ Gary Selvin_____________________
Gary Selvin
Norman Lau
Attorneys for Defendant LEXINGTON
INSURANCE COMPANY, NATIONAL UNION
FIRE INSURANCE COMPANY OF PITTSBURGH,
PA

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Dated: January 17, 2014

COLLIAU CARLUCCIO KEENER MORROW
PETERSON & PARSONS

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____/s/ Kevin M. Haithcox

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Kevin M. Haithcox
Attorney for Defendants NATIONAL FIRE
INSURANCE COMPANY OF HARTFORD (ON
ITS OWN BEHALF AND AS SUCCESSOR BY
MERGER TO TRANSCONTINENTAL
INSURANC E COMPANY), VALLEY FORGE
INSURANCE COMPANY, TRANSPORTATION
INSURANCE COMPANY, CONTINENTAL
CASUALTY COMPANY and THE
CONTINENTAL INSURANCE COMPANY

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____________

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Case No. 3:12-cv-04160-RS

STIPULATION TO AMEND CASE MANAGEMENT ORDER

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Dated: January 17, 2014

LEWIS BRISBOIS BISGAARD & SMITH LLP

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____/s/ Kathleen E. Hegen___________
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Kathleen E. Hegen
Attorney for Defendant ADMIRAL INSURANCE
COMPANY

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Dated: January 17, 2014

SINNOTT, PUEBLA, CAMPAGNE & CURET

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___/s/ Blaise S. Curet
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Blaise S. Curet
Randy M. Marmor
Attorney for Defendant ZURICH AMERICAN
INSURANCE COMPANY

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED,

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DATED: January 17, 2014

_____________________________
Honorable Jon S. Tigar

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Case No. 3:12-cv-04160-RS

STIPULATION TO AMEND CASE MANAGEMENT ORDER