St. Paul Fire and Marine Insurance Company v. Chartis Specialty Insurance Company et al

Filing 53

STIPULATION AND ORDER TO EXTEND FACT DISCOVERY CUT-OFF, EXPERT DISCLOSURES AND EXPERT REBUTTAL DISCLOSURES re 52 STIPULATION WITH PROPOSED ORDER filed by St. Paul Fire and Marine Insurance Company. Fact Discovery due by 8/30/2013. Expert Disclosures due by 9/6/2013. Expert Rebuttal due by 10/11/2013. Signed by Judge Jon S. Tigar on June 14, 2013. (wsn, COURT STAFF) (Filed on 6/14/2013)

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THE AGUILERA LAW GROUP, APLC
A. Eric Aguilera (SBN 192390)
Scott La Salle (Bar No. 188287)
650 Town Center Drive, Suite 100
Costa Mesa, CA 92626
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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

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Plaintiff,

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vs.

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Case No. 3:12-cv-04266-JST
Hon. Jon S. Tigar
Mag. Laurel Beeler

CHARTIS SPECIALTY INSURANCE
COMPANY fka AMERICAN
INTERNATIONAL SPECIALTY LINES
INSURANCE COMPANY, an Illinois
corporation; et al.,

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STIPULATION AND [PROPOSED]
ORDER TO EXTEND FACT
DISCOVERY CUT-OFF, EXPERT
DISCLOSURES AND EXPERT
REBUTTAL DISCLOSURES
Complaint filed: August 13, 2012
Trial date: March 10, 2014

Defendants.

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WHEREAS the parties have scheduled a mediation with mediator Jerry Spolter of JAMS in
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San Francisco to take place on June 28, 2013;
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WHEREAS the Court in this matter, on May 28, 2013, issued an Order setting the fact
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discovery cut-off for July 19, 2013;

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WHEREAS the Court’s Order of May 28, 2013, also set the expert disclosure date for July

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26, 2013, and the expert rebuttal date for August 30, 2013;
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WHERAS, Local Rule 6-2 dictates that the parties may file a stipulation to change the time
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of an event already fixed by Court order;
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WHEREAS given the parties intent to mediate on June 28, 2013, and corresponding desire
not to engage in unnecessary deposition scheduling and preparation or expert consultation prior to
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3:12-cv-04266-JST
STIPULATION AND [PROPOSED] ORDER TO EXTEND FACT DISCOVERY COMPLETION AND EXPERT DISCLOSURE
DATES

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mediation, the parties desire to extend the fact discovery cut-off, expert disclosure and rebuttal

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expert disclosure, each for a period of approximately 40 days;

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WHEREAS such an extension will not affect the schedule for the case, as all other dates will

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remain as set: the dispositive motion filing deadline of November 2, 2013; the expert discovery cut-

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off of November 15, 2013; the pre-trial statement due date of February 18, 2014, the pre-trial

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conference of February 28, 2014, and the trial of March 10, 2014;

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IT IS HEREBY STIPULATED TO AND AGREED that the fact discovery cut-off shall be

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continued from July 19, 2013, to August 30, 2013; the expert disclosure date shall be continued

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from July 26, 2013, to September 6, 2013; and the expert rebuttal disclosure date shall be continued

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from August 30, 2013, to October 11, 2013.

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Dated: June 11, 2013

THE AGUILERA LAW GROUP, APLC

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/s/ Scott La Salle
Scott La Salle, Esq.
Attorneys for Plaintiff ST. PAUL FIRE AND
MARINE INSURANCE COMPANY

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Dated: June 11, 2013

TRENK, DIPASQUALE, DELLA FERA &
SODONO, P.C.

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/s/ Thomas Holden
Thomas Holden, Esq.
Attorneys for Defendants CHARTIS SPECIALTY
INSURANCE COMPANY and LEXINGTON
INSURANCE COMPANY

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Dated: June 13, 2013

ERICKSEN ARBUTHNOT

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/s/ Andrew P. Sclar
Andrew P. Sclar, Esq.
Attorneys for Defendant VALLEY INSURANCE
COMPANY

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3:12-cv-04266-JST
STIPULATION AND [PROPOSED] ORDER TO EXTEND FACT DISCOVERY COMPLETION AND EXPERT DISCLOSURE
DATES

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Dated: June 11, 2013

COLLIAU CARLUCCIO KEENER MORROW
PETERSON & PARSONS

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/s/ Robert C. Christensen
Robert C. Christensen, Esq.
Attorneys for Defendants CONTINENTAL
CASUALTY COMPANY, NATIONAL FIRE
INSURANCE COMPANY OF HARTFORD
(successor by merger to TRANSCONTINENTAL
INSURANCE COMPANY) and
TRANSPORTATION INSURANCE COMPANY

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ORDER

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Pursuant to stipulation of the parties and good cause existing therefore,
IT IS HEREBY ORDERED that:
1) the fact discovery cut-off shall be continued from July 19, 2013, to August 30, 2013;
2)

the expert disclosure date shall be continued from July 26, 2013, to September 6,

2013; and
3)

the expert rebuttal disclosure date shall be continued from August 30, 2013, to

October 11, 2013.
PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: June 14, 2013

_______________________________
Hon. Jon S. Tigar
United States District Judge

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3:12-cv-04266-JST
STIPULATION AND [PROPOSED] ORDER TO EXTEND FACT DISCOVERY COMPLETION AND EXPERT DISCLOSURE
DATES