Migdal v. AMCO Insurance Company

Filing 31

ORDER granting 30 STIPULATION REGARDING DISCOVERY AND MOTION DEADLINES. Fact discovery cutoff: 6/10/2016. Dispositive motions to be heard by 8/8/2016. Pretrial Conference set for 8/22/2016 02:00 PM in Courtroom 12, 19th Floor, San Francisco before Hon. William H. Orrick. Signed by Judge William H. Orrick on 02/17/2016. (jmdS, COURT STAFF) (Filed on 2/17/2016)

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DENTONS US LLP
525 MARKET STREET, 26TH FLOOR
SAN FRANCISCO, CA 94105
[phone]

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Andrew V. Stearns
BUSTAMANTE & GAGLIASSO, APC
333 W. San Carlos St., Ste. 600
San Jose, CA 95110
Tel.: [phone], Fax: [phone]
Email: [e-mail]
Attorney for Plaintiff
MARK MIGDAL
SONIA MARTIN (SBN 191148)
MENGMENG ZHANG (SBN 280411)
DENTONS US LLP
525 Market Street, 26th Floor
San Francisco, CA 94105-2708
Telephone: [phone]
Facsimile: [phone]
E-mail:
[e-mail]
[e-mail]
Attorneys for Defendant
AMCO INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION
MARK MIGDAL, an individual,

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Plaintiff,
vs.

Case No.: 3:15-cv-02496-WHO
STIPULATION REGARDING
DISCOVERY AND MOTION
DEADLINES

AMCO Insurance Company, an Iowa
corporation; and DOES 1 through 50,
inclusive,
Defendants.

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Plaintiff Mark Migdal and Defendant AMCO Insurance Company, through their

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undersigned counsel, hereby stipulate as follows and respectfully request that the Court approve

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and give effect to their stipulation:

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Case No. 3:15-cv-02496-WHO

STIPULATION REGARDING DISCOVERY
AND MOTION DEADLINES

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WHEREAS, AMCO’s counsel requested proposed dates for Plaintiff’s deposition in
early December 2015 and renewed that request on January 7, 2016;
WHEREAS, Plaintiff responded that, due to his extensive travels outside the country, the

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first date on which he could be available for deposition would be during the week of February

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22, 2016;

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WHEREAS, the parties have now scheduled Plaintiff’s deposition for March 3, 2016;

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WHEREAS, the parties wish to allow sufficient time following Plaintiff’s deposition for

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DENTONS US LLP
525 MARKET STREET, 26TH FLOOR
SAN FRANCISCO, CA 94105
[phone]

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follow-up discovery;
WHEREAS, a brief continuance of the discovery and dispositive motion deadlines in this
case will not impact the September 19, 2016 bench trial date in this matter;
IT IS HEREBY STIPULATED AND AGREED THAT the case management schedule
should be revised as follows:

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Current Deadline

New Deadline

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Non-expert discovery cut-off:

April 8, 2016

June 10, 2016

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FRCP 26(a)(2) expert disclosures:

April 22, 2016

May 20, 2016

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FRCP 26(a)(2) rebuttal disclosures:

May 10, 2016

June 7, 2016

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Expert Discovery cut-off:

June 10, 2016

July 8, 2016

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Dispositive pre-trial motion hearing cut-off: June 10, 2016

August 8, 2016

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Pretrial conference statements:

June 24, 2016

August 15, 2016

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Pretrial conference:

July 11, 2016

August 22, 2016

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Respectfully submitted,
Dated: February 16, 2016

BUSTAMANTE & GAGLIASSO, APC

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By

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/s/ Andrew V. Stearns
ANDREW V. STEARNS

Attorneys for Plaintiff
MARK MIGDAL

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Case No. 3:15-cv-02496-WHO

STIPULATION REGARDING DISCOVERY
AND MOTION DEADLINES

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Dated: February 16, 2016

DENTONS US LLP

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By

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/s/ Sonia Martin
SONIA MARTIN

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Attorneys for Defendant
AMCO INSURANCE COMPANY

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FILER’S ATTESTATION:
Pursuant to Local Rule 5-(i)(3) regarding signatures, I attest under penalty of perjury that the
concurrence in the filing of this document has been obtained from its signatories.
DATED: February16, 2016

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By:

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/s/ Sonia Martin
SONIA MARTIN

DENTONS US LLP
525 MARKET STREET, 26TH FLOOR
SAN FRANCISCO, CA 94105
[phone]

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ORDER
This Stipulation is DENIED without prejudice. The parties shall incorporate their scheduling
requests in the Joint Case Management Conference Statement due on March 1, 2016 and be prepared
to discuss this at the hearing on March 9, 2016.

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DATED: February 17, 2016
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_______________________________
HON. WILLIAM H. ORRICK
UNITED STATES DISTRICT JUDGE

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Case No. 3:15-cv-02496-WHO

STIPULATION REGARDING DISCOVERY
AND MOTION DEADLINES