Flores et al v. State Farm General Insurance Company

Filing 32

Order by Hon. Vince Chhabria granting 31 Stipulation to Partially Revise the Court's Scheduling Order.(knm, COURT STAFF) (Filed on 10/2/2014)

1 STEPHEN M. HAYES (SBN 83583)
STEPHEN P. ELLINGSON (SBN 136505)
2 CHERIE M. SUTHERLAND (SBN 217992)
HAYES SCOTT BONINO ELLINGSON & McLAY, LLP
3 203 Redwood Shores Pkwy., Ste. 480
Redwood City, California 94065
4 Telephone: [phone]
Facsimile: 650.637.8071
5 Attorneys for Defendant
STATE FARM GENERAL INSURANCE COMPANY
6
J. EDWARD KERLEY (SBN 175695)
7 DYLAN L. SCHAFFER (SBN 153612)
HEREFORD KERLEY LLP
8 1939 Harrison Street, Suite 500
Oakland, California 94612
9 Telephone: [phone]
Facsimile: 510.228-0350
10
Attorney for Plaintiffs
11 JOSE and YADIRA FLORES dba LA ROSA MARKET
12
UNITED STATES DISTRICT COURT

13

NORTHERN DISTRICT OF CALIFORNIA

14

15 JOSE FLORES, an individual, and
YADIRA FLORES, an individual, dba
16 LA ROSA MARKET,

CASE NO. CV 13-05348 VC
STIPULATION AND [PROPOSED]
ORDER TO PARTIALLY REVISE
THE COURT’S SCHEDULING
ORDER

Plaintiffs,

17
v.

18

19 STATE FARM GENERAL INSURANCE
COMPANY, an Illinois Company, and DOES
20 1through 15,
Defendants.

21
22

Plaintiffs and State Farm General Insurance Company (“State Farm”), by and through their

23

24 respective counsel, hereby stipulate to revise the Court’s February 18, 2014 Pretrial Schedule (Dkt
25 18) as follows:
I.
26
RECITALS
1.

27

The parties have been working diligently toward moving this case forward in an

28 efficient, expeditious manner. The current deadline to complete fact discovery is October 24, 2014.
547972

-1STIPULATION AND [PROPOSED] ORDER TO PARTIALLY REVISE THE COURT’S
SCHEDULING ORDER - CASE NO. CV 13-05348 VC

1 Despite the parties’ diligent efforts and cooperation to complete the depositions of fact witnesses,
2 there are certain fact witnesses whose depositions cannot be scheduled by that date due to the lack of
3 mutually available dates between and among counsel and the remaining witnesses. For that reason,
4 the parties have agreed to stipulate to a proposed order extending the deadline for fact discovery, and
5 the deadlines for expert disclosure, rebuttal disclosure and expert discovery, to enable the parties to
6 complete fact and expert discovery without incurring undue burden and expense.
2.

7

The parties do not seek to continue any deadlines other than the deadlines for fact

8 discovery, expert disclosure, rebuttal disclosure and expert discovery. The parties do not seek to
9 continue the trial date or the pretrial conference date.
10
II.
STIPULATION

11
12

The parties hereby stipulate to the following revisions to the court’s Pretrial Schedule:

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1. Discovery Cutoff

January 30, 2015
(currently November 21, 2014)

2. Expert Rebuttal

February 13, 2015
(currently December 19, 2014)

2. Expert Discovery Cutoff

15

January 16, 2015
(currently October 24, 2014)

2. Expert Disclosure

14

February 27, 2015
(currently January 30, 2015)

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17
18
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Dated: September 30, 2014

HEREFORD KERLEY, LLP

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23
By
24
25
26

/S/ Dylan L. Schaffer
J. EDWARD KERLEY
DYLAN L. SCHAFFER
Attorney for Plaintiffs
JOSE and YADIRA FLORES dba LA ROSA
MARKET

27
28
547972

-2STIPULATION AND [PROPOSED] ORDER TO PARTIALLY REVISE THE COURT’S
SCHEDULING ORDER - CASE NO. CV 13-05348 VC

1 Dated: September 30, 2014

HAYES SCOTT BONINO ELLINGSON & McLAY, LLP

2
By
3
4
5

/S/ Stephen P. Ellingson
STEPHEN M. HAYES
STEPHEN P. ELLINGSON
CHERIE M. SUTHERLAND
Attorneys for Defendant
STATE FARM GENERAL INSURANCE
COMPANY

6
[PROPOSED] ORDER

7
8

Pursuant to the parties’ stipulation, the Pretrial Schedule is revised as follows:

9
1. Discovery Cutoff

January 16, 2015
(currently October 24, 2014)

2. Expert Disclosure

January 30, 2015
(currently November 21, 2014)

2. Expert Rebuttal

February 13, 2015
(currently December 19, 2014)

2. Expert Discovery Cutoff

10

February 27, 2015
(currently January 30, 2015)

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12
13
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15
16
17

The remaining dates and deadlines set forth in the Civil Minutes dated February 18, 2014 (Dkt

18 18) remain unchanged.
19

S

Dated: October 1

, 2014

UNIT
ED

HONORABLE VINCE CHHABRIAD
UNITED STATES DISTRICT COURT FOR THE
RDERE
IS SO O CALIFORNIA
T
NORTHERNIDISTRICT OF

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547972

-3STIPULATION AND [PROPOSED] ORDER TO PARTIALLY REVISE THE COURT’S
SCHEDULING ORDER - CASE NO. CV 13-05348 VC