Batts v. Bankers Life & Casualty Company

Filing 57

ORDER GRANTING 56 STIPULATION WITH PROPOSED ORDER Re Non-Expert Discovery and Dispositive Motion Deadlines filed by Bankers Life & Casualty Company. Signed by Judge Susan Illston on 9/26/14. (tfS, COURT STAFF) (Filed on 9/30/2014)

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WILLIAM HAYS WEISSMAN, Bar No. 178976
JOHANNA R. CARNEY, Bar No. 277946
LITTLER MENDELSON, P.C.
Treat Towers
1255 Treat Boulevard, Suite 600
Walnut Creek, California 94597
Telephone:
925.932.2468
Facsimile:
925.946.9809
Email:
[e-mail]
[e-mail]
Attorneys for Defendant
BANKERS LIFE AND CASUALTY COMPANY
LEEDS DISSTON, Esq. SBN 45016
CASALINA & DISSTON
418 Third Street, Suite 101
Oakland, California 94607
Telephone [phone]
Facsimile [phone]
[e-mail]
Attorneys for Plaintiff
TIMOTHY BATTS

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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TIMOTHY BATTS,

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Plaintiff,
v.
BANKERS LIFE AND CASUALTY
COMPANY and DOES 1 to 50,
Defendants.

Case No. 3:13-cv-04394 SI
STIPULATION AND [PROPOSED]
ORDER RE: NON-EXPERT DISCOVERY
AND DISPOSITIVE MOTION
DEADLINES
Judge: Hon. Susan Illston
Dept: Courtroom 10 – 19th Floor
Trial Date: April 6, 2015

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LITTLER MENDELSON, P.C.
Treat Towers
1255 Treat Boulevard
Suite 600
Walnut Creek, CA 94597
925.932.2468

Pursuant to Civil Local Rule 7-12, Plaintiff Timothy Batts (“Plaintiff”) and Defendant
Bankers Life and Casualty Company (“Defendant”) (collectively, “the Parties”) by and through their
respective counsel, hereby agree and stipulate to the following:
STIPULATION AND [PROPOSED] ORDER RE:
NON-EXPERT DISCOVERY AND DISPOSITIVE
MOTION DEADLINES

1.

(Case No. 3:13-cv-04394-SI)

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1.

Pursuant to the Court’s February 10, 2014, Pretrial Preparation Order, the

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non-expert discovery cutoff is presently September 30, 2014. Trial is currently set to commence on

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April 6, 2015. Pursuant to Civil Local Rule 37-3, the last day to file non-expert discovery motions

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to compel is presently October 7, 2014.

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Preparation Order, the deadline to file dispositive motions is presently October 17, 2014.

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2.

Pursuant to the Court’s February 10, 2014, Pretrial

Due to scheduling and other conflicts, the Parties are unable to complete all

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non-expert depositions prior to September 30, 2014. The Parties have agreed on the following

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schedule for depositions:

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a. Defendant will take Plaintiff Timothy Batts’ deposition on September 29,

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2014.

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b. Plaintiff will take the depositions of Defendant’s employees Roger Cardenas,

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Robert Hadidian, and Mona Wolfe between October 1st and October 9th, with

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the exact dates to be agreed upon via e-mail as soon as practicable, and

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Plaintiff to issue amended deposition notices accordingly.

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3.

To allow for time to for the Parties to take these depositions, supplement

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disclosures, and to conduct other necessary discovery, the Parties respectfully request that the non-

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expert discovery cutoff be postponed until October 10, 2014. The Parties further request that the

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deadline to file non-expert discovery motions to compel be set for October 17, 2014, pursuant to

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Civil Local Rule 37-3.

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4.

In addition, to allow time for deposition transcripts to be ordered and made

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available prior to the dispositive motion deadline, the Parties respectfully request that the deadline to

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file dispositive motions be re-set for October 27, 2014.

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LITTLER MENDELSON, P.C.
Treat Towers
1255 Treat Boulevard
Suite 600
Walnut Creek, CA 94597
925.932.2468

STIPULATION AND [PROPOSED] ORDER RE:
NON-EXPERT DISCOVERY AND DISPOSITIVE
MOTION DEADLINES

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(Case No. 3:13-cv-04394-SI)

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IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD.

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DATED:_9/26/14_______

___/s/ Leeds Disston _________________
Leeds Disston
CASALINA & DISSTON
Attorneys for Plaintiff
Timothy Batts

DATED:_9/26/14_______

___/s/ Johanna R. Carney __________________
William Weissman
Johanna Carney
LITTLER MENDELSON
Attorneys for Defendant
BANKERS LIFE AND CASUALTY
COMPANY

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I, the filer of this document, attest that all other signatories listed, and on whose behalf the filing is

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submitted, concur in the filing’s content and have authorized the filing.

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Dated: September 26, 2014

/S/ Johanna R. Carney
William Weissman
Johanna R. Carney
LITTLER MENDELSON, P.C.
Attorneys for Defendant
BANKERS LIFE AND CASUALTY COMPANY

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[PROPOSED] ORDER
1.

The non-expert discovery cutoff in the above-mentioned case shall be re-set for

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October 10, 2014.

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2.

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October 17, 2014.

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3.

The deadline to file non-expert discovery motions to compel shall be re-set for
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The deadline to file dispositive motions shall be re-set for October 27, 2014
HEARING SET: 12/5/14

PURSUANT TO STIPULATION, IT IS SO ORDERED.

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9/26/14
DATED:_____________

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LITTLER MENDELSON, P.C.
Treat Towers
1255 Treat Boulevard
Suite 600
Walnut Creek, CA 94597
925.932.2468

STIPULATION AND [PROPOSED] ORDER RE:
NON-EXPERT DISCOVERY AND DISPOSITIVE
MOTION DEADLINES

_____________________________________
United States District Judge Illston
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(Case No. 3:13-cv-04394-SI)