Saarman Construction, Ltd v. Ironshore Specialty Insurance Company

Filing 99

STIPULATION AND ORDER re 98 STIPULATION WITH PROPOSED ORDER STIPULATION TO EXTEND DEADLINE FOR EXPERT DEPOSITIONS filed by Ironshore Specialty Insurance Company. Signed by Judge Jon S. Tigar on October 11, 2016. (wsn, COURT STAFF) (Filed on 10/11/2016)

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SAMUEL F. BARNUM (No. 75767)
[e-mail]
LAW OFFICES OF SAMUEL F. BARNUM
4302 Redwood Highway, Suite 100
San Rafael, CA 94903
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
SAARMAN CONSTRUCTION, LTD

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WILLIAM C. MORISON (No. 99981)
[e-mail]
JOANNE M. WENDELL (No. 191785)
[e-mail]
MORISON & PROUGH, LLP
2540 Camino Diablo, Suite 100
Walnut Creek, CA 94597
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
IRONSHORE SPECIALTY
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

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SAARMAN CONSTRUCTION, LTD., a
California Corporation,
Plaintiff,

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v.

Case No. 3:15-cv-03548-JST
STIPULATION TO EXTEND DEADLINE
FOR EXPERT DEPOSITIONS; [PROPOSED]
ORDER

IRONSHORE SPECIALTY INSURANCE
COMPANY, an Arizona Corporation; and
DOES 1 through 50, inclusive,
Defendants.
WHEREAS, the deadline to take expert depositions in this action pursuant to the Court’s
Order of August 26, 2016 (ECF No. 95), is October 21, 2016;
WHEREAS, Defendant Ironshore Specialty Insurance Company (“Ironshore”) timely

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disclosed its expert and provided its expert’s report to Plaintiff Saarman Construction, Ltd.

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(“Saarman”) on September 23, 2016, in accordance with the Court’s Order;
-1STIPULATION TO EXTEND DEADLINE FOR EXPERT DEPOSITIONS
3:15-cv-03548-JST

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WHEREAS, counsel for Ironshore has a pre-scheduled vacation during the second half of

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October 2016, and while counsel can conduct the deposition of Saarman’s expert on October 17,

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2016, they are unable to take Ironshore’s expert deposition until November 1, 2016;

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AND WHEREAS, the deadline for taking expert depositions can be extended from

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October 21 to November 2, 2016, without any impact on the Court’s schedule, as the discovery

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phase in this action is otherwise closed, dispositive motions have already been heard, the pre-trial

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conference is scheduled for January 4, 2017, and trial is scheduled to begin on January 30, 2017.

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IT IS HEREBY STIPULATED AND AGREED BY AND BETWEEN Plaintiff Saarman

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and Defendant Ironshore, by and through their designated counsel, that the deadline to take expert

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depositions in this action be extended from October 21, 2016, to November 2, 2016.

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Dated: October 10, 2016

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Respectfully submitted,
LAW OFFICES OF SAMUEL F. BARNUM

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By:/s/ Samuel F. Barnum
Samuel F. Barnum

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Attorneys for Plaintiff
SAARMAN CONSTRUCTION, LTD

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Dated: October 10, 2016

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MORISON & PROUGH, LLP

By:/s/ William C. Morison
William C. Morison

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Attorneys for Defendant
IRONSHORE SPECIALTY INSURANCE CO.

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, AND FOR GOOD CAUSE SHOWN, IT IS SO ORDERED.

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October 11, 2016
DATED: __________________

__________________________________
Honorable Jon S. Tigar

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ID405

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-2STIPULATION TO EXTEND DEADLINE FOR EXPERT DEPOSITIONS
3:15-cv-03548-JST