The opinion of the court was delivered by: Howard R. Lloyd Magistrate Judge of the United States District Court for the Northern District of California
BOHM, MATSEN, KEGEL & AGUILERA, LLP A. Eric Aguilera (SBN 192390) Kari M. Myron (SBN 158592) 695 Town Center Drive, Suite 700 Costa Mesa, CA 92626 T: 714-384-6500 F: 714-384-6501 5 email@example.com firstname.lastname@example.org COLE, LETHER, WATHEN, LEID & HALL, P.C. Thomas Lether, Esq. Pro Hac Vice 1000 Second Avenue Suite 1300 Seattle, WA 98104-1802 T: (206) 622-0494 email@example.com Attorneys for Defendant TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA
Hon. Judge: Edward J. Davilla Magistrate Judge: Howard R. Lloyd
STIPULATION AND [PROPOSED] PROTECTIVE ORDER IN RE
SUPPLEMENTAL RESPONSES TO TRAVELERS PROPERTY CASUALTY DISCOVERY
FOLLOWING MEET AND CONFER
WHEREAS Kaufman & Broad Monterey Bay and KB Home South Bay, Inc.
"KB Home") propounded certain discovery to Travelers Property
Casualty Company of America
("Travelers") regarding (1) the claims history of its named insured,
Norcraft Companies, (2) the 27 additional insured claims history under
the policies issued to Norcraft Companies, and (3)
information with respect to the status of the remaining limits under
certain of those policies issued 2 to Norcraft Companies that are
potentially implicated in the underlying construction defect action
entitled Aldrich, et al. v. KB Home, et al. and related
cross-complaint, in the Monterey County
Superior Court, Case Number M 94490 (the "Aldrich Action"), some of which became the subject 5 of dispute between KB Home and Travelers. Such disputed discovery consisted of the following:
1. Interrogatories (Set 2), numbers 9-25 as propounded by KB Home South Bay, Inc.;
2. Interrogatories (Set 2), numbers 20-25 as propounded by Kaufman & Broad Monterey Bay;
3. Request for Production (Set 2), numbers 69, 70, 71, and 72, as propounded by KB Home;
4. Requests for Admission (Set 3), numbers 15-19 as propounded by KB Home South Bay, Inc.
WHEREAS Travelers initially responded to the aforementioned discovery on May 27, 2011.
WHEREAS KB Home filed Motions to Compel Further Responses ("KB Home Motions") [Dkts. 71 through 74]; and issued directives to comply with the Standing ...