Walker et al v. Unitrin Auto & Home Insurance Company et al

Filing 72

STIPULATION AND ORDER re 71 STIPULATION WITH PROPOSED ORDER (Joint) to Continue Deadline to File Discovery Motions filed by Financial Indemnity Company Discovery due by 10/22/2015. Signed by Judge Edward M. Chen on 10/19/15. (bpfS, COURT STAFF) (Filed on 10/19/2015)

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SEDGWICK LLP
NICHOLAS J. BOOS (State Bar No. 233399)
[e-mail]
KARA L. DIBIASIO (State Bar No. 294547)
[e-mail]
333 Bush Street, 30th Floor
San Francisco, CA 94104-2834
Telephone:
415.781.7900
Facsimile:
415.781.2635
Attorneys for Defendant
FINANCIAL INDEMNITY COMPANY
LAW OFFICES OF JOHN FITZPATRICK VANNUCCI
JOHN FITZPATRICK VANNUCCI (State Bar No. 174329)
100 Montgomery Street, Suite 1600
San Francisco, CA 94104
Telephone:
415.981.7500
Facsimile:
415.981.5700
Attorney for Plaintiff
MICHAEL WALKER

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MICHAEL WALKER, TASHELL
MITCHEL,

Case No. 3:14-cv-03161--EMC
JOINT STIPULATION AND
[PROPOSED] ORDER TO CONTINUE
DEADLINE TO FILE DISCOVERY
MOTIONS

Plaintiffs,
v.
UNITRIN AUTO AND HOME INSURANCE
COMPANY, FINANCIAL INDEMNITY
COMPANY, UNITRIN DIRECT
PROPERTY AND CASUALTY COMPANY
and DOES 1 TO 25, inclusive,

[CIVIL L.R. 6-1(b); 6-2; 7-12]

Defendants.

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82266338v1

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3:14-cv-03161--EMC

JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE TO FILE DISCOVERY
MOTIONS

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Plaintiff Michael Walker and defendant Financial Indemnity Company ("FIC"), through

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their respective undersigned counsel and pursuant to Civil L.R. 6-1(b), 6-2, and 7-12, hereby

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respectfully submit the following Joint Stipulation and [Proposed] Order to Continue the

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Deadline to File Expert Discovery Motions.
STIPULATION

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WHEREAS, the Court issued a Scheduling Order on July 31, 2015 setting trial and pre-

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trial deadlines, including a deadline to complete non-expert discovery by October 8, 2015 (ECF

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No. 65);

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WHEREAS, pursuant to Civil L.R. 37-3, the deadline to file motions to compel fact
discovery is October 15, 2015;
WHEREAS, the parties are currently still attempting to meet and confer to resolve

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outstanding issues regarding fact discovery and request additional time to continue these efforts

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before filing a joint letter brief with the Court regarding these issues;

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WHEREAS, the parties hereby stipulate and respectfully request that the Court continue

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the deadline to file a joint letter brief regarding fact discovery until October 22, 2015.

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DATED: October 15,2015

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SEDGWICK LLP

By:~&Boos --l
9gNiCks

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J.
Kara L. DiBiasio
Attorneys for Defendant
FINANCIAL INDEMNITY COMPANY

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DATED: October 15, 2015
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Attestation Regarding Signatures: Pursuant to Civil Local Rule 5-1 (i)(3), Kara L. DiBiasio
hereby attests that concurrence in the filing of the document has been obtained from each of the
other signatories identified above, which shall serve in lieu of their signatures on the document.

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82266338vl

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3:14-cv-03161--EM

JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE TO FILE DISCOVERY
MOTIONS

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, it is hereby ORDERED that the deadline for the

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parties to file joint letter briefs regarding non-expert discovery shall be continued until October

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22, 2015.

ER

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R NIA

FO

dwa
Judge E

H

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RT

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hen

rd M. C

NO

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ED

D
HON. EDWARD ERCHEN
SO OR M.
IT STATES DISTRICT JUDGE
UNITED IS

LI

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S DISTRICT
TE
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TA

A

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10/19/15

RT
U
O

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DATED:

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IT IS SO ORDERED.

UNIT
ED

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N

F
D IS T IC T O
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82266338v1

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3:14-cv-03161--EMC

JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEADLINE TO FILE DISCOVERY
MOTIONS