Napa Valley Limoncello LLC et al v. Nationwide Agribusiness Insurance Company

Filing 33

ORDER by Judge Haywood S. Gilliam, Jr. GRANTING 32 Stipulation TO EXTEND EXPERT REPORT DEADLINES ONLY. Opening Reports due by 4/30/2025. Rebuttal Reports due by 5/28/2025. (ndr, COURT STAFF) (Filed on 3/11/2025)

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SONIA MARTIN (SBN 191148)
[e-mail]
MORDECAI BOONE (SBN 196811)
[e-mail]
EMILY NOZICK (SBN 201050)
[e-mail]
THOMAS D’ANTONIO (SBN 316472)
[e-mail]
DENTONS US LLP
1999 Harrison Street, Suite 1210
Oakland, CA 94612
Telephone: [phone]
Facsimile: 415 882 0300

Attorneys for Defendant
NATIONWIDE AGRIBUSINESS
INSURANCE COMPANY

DENTONS US LLP
1999 HARRISON STREET, SUITE 1210
OAKLAND, CALIFORNIA 94612
415 882 5000

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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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NAPA VALLEY LIMONCELLO LLC, d/b/a
NAPA VALLEY DISTILLERY, a California
limited liability company; NAPASTAK, INC.,
d/b/a NAPASTAK CELLARS, a California
corporation,

Case No. 4:24-cv-3243- HSG
RESUBMITTED STIPULATION AND
ORDER TO EXTEND EXPERT
REPORT DEADLINES ONLY

Plaintiffs,
v.
NATIONWIDE AGRIBUSINESS
INSURANCE CO., an Iowa corporation, and
DOES 1-10,

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Defendants.

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Pursuant to Federal Rule of Civil Procedure 16(b)(4), Local Rules 143 and 144, and the Honorable

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Haywood S Gilliam, Jr., plaintiffs Napa Valley Limoncello LLC, d/b/a Napa Valley Distillery; Napastak,

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Inc., d/b/a Napastak Cellars and defendant Nationwide Agribusiness Insurance Co., by and through their

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respective counsels of record, stipulate and agree as follows and respectfully request entry of an order giving

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effect to their stipulation:
CASE NO. 4:24-cv-3243- HSG
US_ACTIVE\129468529\V-2

RESUBMITTED STIP. & O.
TO EXTEND EXPERT REPORT DEADLINES ONLY

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WHEREAS, the parties have been engaging in extensive discovery including, but not limited to:

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requests for production of documents, requests for admission, interrogatories, negotiating and stipulating to

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a protective order, supplemental document productions, meeting and conferring to work through multiple

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discovery disputes without involving the court, and propounding numerous third party subpoenas;

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WHEREAS, the parties have taken two depositions and need to conduct three more prior to the
disclosure of expert reports;

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WHEREAS, the parties, through no fault of their own, have experienced delays in the production
of third party testing documents necessary to conduct the remaining depositions;

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DENTONS US LLP
1999 HARRISON STREET, SUITE 1210
OAKLAND, CALIFORNIA 94612
415 882 5000

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WHEREAS, pursuant to Local Rule 144(b), the Court has granted one prior request to modify the
deadlines in this case (Dkt. 25);

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WHEREAS, the current case schedule is as follows:

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Event

Current Deadline

Exchange of opening expert reports

March 28, 2025

Exchange of rebuttal expert reports

May 5, 2025

Close of fact and expert discovery

June 27, 2025

Dispositive pre-trial motion hearing deadline

August 15, 2025

Pretrial conference:

November 4, 2025

Trial

November 17, 2025

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WHEREAS, a continuance of the expert report exchange deadlines is necessary to provide the
parties adequate time to complete the depositions necessary as bases for expert reports;

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WHEREAS, the parties seek to extend the expert exchange report deadlines only;

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WHEREAS, this will not affect any other dates in the schedule;

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WHEREAS, the parties agree to move the two dates below as follows:
CASE NO. 4:24-cv-3243- HSG
US_ACTIVE\129468529\V-2

RESUBMITTED STIP. & O.
TO EXTEND EXPERT REPORT DEADLINES ONLY

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Event

Current Deadline

Proposed Deadline

Exchange of opening expert
reports

March 28, 2025

April 30, 2025

Exchange of rebuttal expert
reports

March 5, 2025

May 28, 2025

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DENTONS US LLP
1999 HARRISON STREET, SUITE 1210
OAKLAND, CALIFORNIA 94612
415 882 5000

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NOW, THEREFORE, IT IS AGREED AND STIPULATED that:

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Good cause exists to continue the expert disclosure deadlines in this matter, set forth in the Court’s

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Order granting the parties’ stipulated request to modify the case schedule (Dkt. 25) as set forth in the table

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above.

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conference at which time new dates may be selected.

Alternatively, the parties respectfully request that the Court set a further case management

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The parties respectfully request the Court adopt the foregoing stipulated as the order of the Court.

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IT IS SO STIPULATED.

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Dated: March 10, 2025

DENTONS US LLP

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By: /s/ Mordecai Boone
Mordecai Boone

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Attorneys for Defendant
NATIONWIDE AGRIBUSINESS INSURANCE
COMPANY

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Dated: March 10, 2025

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BRIGGS & ALEXANDER, APLC
Jeffrey Weber, Esq.

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By: /s/ Jeffrey Weber
Jeffrey Weber

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Attorneys for Plaintiffs
NAPA VALLEY LIMONCELLO LLC, d/b/a
NAPA VALLEY DISTILLERY; NAPASTAK,
INC., d/b/a NAPASTAK CELLARS

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CASE NO. 4:24-cv-3243- HSG
US_ACTIVE\129468529\V-2

RESUBMITTED STIP. & O.
TO EXTEND EXPERT REPORT DEADLINES ONLY

ORDER

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Pursuant to the above-stipulation, and for good cause shown, the Court hereby continues

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the expert report deadlines set forth in the Court’s Order granting the parties’ stipulated request to

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modify the case schedule (Dkt. 25) and the new case schedule is as follows:

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Event

Deadline

Exchange of opening expert reports

April 30, 2025

Exchange of rebuttal expert reports

May 28, 2025

Close of fact and expert discovery

June 27, 2025

Dispositive pre-trial motion hearing
deadline

August 15, 2025

Pretrial conference:

November 4, 2025

Trial

November 17, 2025

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DENTONS US LLP
1999 HARRISON STREET, SUITE 1210
OAKLAND, CALIFORNIA 94612
415 882 5000

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IT IS SO ORDERED.
Dated: 3/11/2025

By: ________________________________
The Honorable Haywood S Gilliam, Jr
United States District Judge

CASE NO. 4:24-cv-3243- HSG

RESUBMITTED STIP. & O.
TO EXTEND EXPERT REPORT DEADLINES ONLY

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US_ACTIVE\129468529\V-2