Filed: Dec. 06, 2017
Latest Update: Dec. 06, 2017
Summary: JOINT STIPULATION AND ORDER TO CONTINUE DISCOVERY AND DISPOSITIVE MOTION DEADLINES MORRISON C. ENGLAND, JR. , District Judge . Pursuant to Local Rule 143 and the Court's Order Extending Discovery Deadlines (Dkt. #17), Plaintiff Tammy Lynn Logan ("Plaintiff") and Defendants Patriot National, Inc., Patriot Risk Services, Inc., Patriot Claim Services, Inc., and Patriot Risk Consultants, Inc., erroneously sued as "Patriot Risk Management, Inc." (collectively, "Defendants"), by and through their
Summary: JOINT STIPULATION AND ORDER TO CONTINUE DISCOVERY AND DISPOSITIVE MOTION DEADLINES MORRISON C. ENGLAND, JR. , District Judge . Pursuant to Local Rule 143 and the Court's Order Extending Discovery Deadlines (Dkt. #17), Plaintiff Tammy Lynn Logan ("Plaintiff") and Defendants Patriot National, Inc., Patriot Risk Services, Inc., Patriot Claim Services, Inc., and Patriot Risk Consultants, Inc., erroneously sued as "Patriot Risk Management, Inc." (collectively, "Defendants"), by and through their ..
More
JOINT STIPULATION AND ORDER TO CONTINUE DISCOVERY AND DISPOSITIVE MOTION DEADLINES
MORRISON C. ENGLAND, JR., District Judge.
Pursuant to Local Rule 143 and the Court's Order Extending Discovery Deadlines (Dkt. #17), Plaintiff Tammy Lynn Logan ("Plaintiff") and Defendants Patriot National, Inc., Patriot Risk Services, Inc., Patriot Claim Services, Inc., and Patriot Risk Consultants, Inc., erroneously sued as "Patriot Risk Management, Inc." (collectively, "Defendants"), by and through their counsel of record hereby stipulate and request that the Court enter and Order as follows:
WHEREAS, Plaintiff commenced this action on April 22, 2016 in the Superior Court of the State of California for the County of Sacramento [Dkt. #1, Exhibit A ("Complaint")];
WHEREAS, Defendants removed this action to this Court on June 22, 2016 [Dkt. #1];
WHEREAS, on June 22, 2016 the Court issued an Initial Pretrial Scheduling Order, which scheduled deadlines for discovery, disclosure of expert witness and dispositive motions [Dkt. #2];
WHEREAS, the parties sought and the Court approved the parties' stipulation to extend all pretrial deadlines to accommodate out of state depositions;
WHEREAS, the Court's Order set, inter alia, the following deadlines [Dkt. #14]:
Event New Date
Fact Discovery October 18, 2017
Initial Expert Disclosures December 18, 2018
Rebuttal Expert Disclosures January 16, 2018
Dispositive Motion Filing February 15, 2018
Deadline
Notice of Trial Readiness 30 days after receiving
Court's ruling on the last field dispositive
motions
WHEREAS, the parties participated in mediation on October 10, 2017 and were unable to reach a settlement;
WHEREAS the parties required additional time to continue negotiations, and to complete discovery if negotiations are unsuccessful;
WHEREAS, the parties previously sought and the Court approved to extend by 30 days the fact discovery deadline [Dkt. #17];
WHEREAS, the parties are still engaged in settlement discussions and need additional time to continue negotiations, and to complete fact discovery and retain experts if negotiations are unsuccessful;
WHEREAS, the proposed extension to the discovery will not impact the trial date of this case;
WHEREAS, in light of the above, good cause exists to extend the current discovery, expert disclosure schedule and dispositive motion schedule;
NOW THEREFORE, in consideration of the foregoing, the parties, by and through their undersigned counsel, hereby stipulate, agree and request that the Court enter an Order amending the deadlines in the Court's October 30, 2017 Order as follows:
Event Current Date New Date
Fact Discovery November 17, 2017 January 18, 2018
Initial Expert Disclosures December 18, 2017 February 18, 2018
Rebuttal Expert Disclosures January 16, 2018 March 16, 2018
Dispositive Motion Filing February 15, 2017 April 16, 2018
Notice of Trial Readiness 30 days after receiving No change
Court's ruling on the last
field dispositive motions
IT IS SO STIPULATED.
IT IS SO ORDERED.
