Greenbaum v. The Burlington Insurance Company

Filing 35

STIPULATION AND ORDER RE 34 TO EXTEND THE EXPERT DISCOVERY CUT-OFF. Signed by Judge Richard Seeborg on 3/1/17. (cl, COURT STAFF) (Filed on 3/1/2017)

1 THOMAS HOLDEN (No. 130277)
GREENBERG TRAURIG, LLP
2 Four Embarcadero Center, Suite 3000
San Francisco, CA 94111
[phone]
3 Telephone:
Facsimile:
[phone]
4 [e-mail]
5 Attorneys for Defendant
THE BURLINGTON
6 INSURANCE COMPANY
7
8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10
11 PETER GREENBAUM,
12

Plaintiff;

13 v.

Case No. 16-cv-00511-RS
STIPULATION TO EXTEND THE
EXPERT DISCOVERY CUT-OFF;
[PROPOSED] ORDER

14 THE BURLINGTON INSURANCE
COMPANY,
15
Defendant.
16
17

WHEREAS, Defendant’s rebuttal expert disclosure is due on March 2, 2017;

18

WHEREAS, the cut-off date for expert discovery in this matter is currently March 7, 2017;

19

WHEREAS, the parties’ expert witnesses are not available for deposition until after March 7,

20 2017;
21

WHEREAS, Defendant’s motion for summary judgment is scheduled for hearing on March

22 16, 2017;
23

WHEREAS, the parties agree that it would be mutually beneficial to conduct expert

24 depositions in April 2017;
25

WHEREAS, there has been one previous time modification in this case, in that the Court

26 approved a stipulation to take certain depositions after the non-expert discovery cut-off, but that
27 stipulation was later mooted by the Court continuing Defendant’s motion for summary judgment to
28 permit some of those depositions;
STIPULATION TO EXTEND EXPERT DISCOVERY CUT-OFF; [PROPOSED] ORDER
CASE NO. 16-CV-00511-RS

1

WHEREAS, no other deadlines will be affected by extending the expert discovery cut-off;

2

THEREFORE, the parties to this action, through their counsel of record, hereby STIPULATE

3 as follows:
4

Defendant shall take the deposition of plaintiff’s expert witness, David Frangiamore, in

5 Phoenix, Arizona, on April 11, 2017;
6

Plaintiff shall take the deposition of defendant’s expert witness, Gary Selvin, at the office of

7 Plaintiff’s counsel, on April 18, 2017;
8

The cut-off date for expert discovery is hereby extended to April 18, 2017, to allow for these

9 depositions, and following completion of these depositions expert discovery shall be closed.
10 Dated: March 1, 2017

GREENBERG TRAURIG, LLP

11
By:

12

/s/ Thomas Holden
Thomas Holden

13
Attorneys for Defendant
THE BURLINGTON INSURANCE
COMPANY

14
15
16 Dated: March 1, 2017

MILES & WESTBROOK

17
By:

18

/s/ Brian B. Miles
Brian B. Miles

19
Attorneys for Plaintiff
PETER GREENBAUM

20
21

22 PURSUANT TO STIPULATION, IT IS SO ORDERED.
23
24 Dated: _______________, 2017
3/1
25
26

Richard Seeborg
United States District Judge

27
28
2
STIPULATION TO EXTEND EXPERT DISCOVERY CUT-OFF; [PROPOSED] ORDER
CASE NO. 16-CV-00511-RS