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Maryland Casualty Company, Steadfast v. Financial Pacific Insurance Company

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


May 25, 2012

MARYLAND CASUALTY COMPANY, STEADFAST INSURANCE COMPANY, AND
ASSURANCE COMPANY OF AMERICA, PLAINTIFFS,
v.
FINANCIAL PACIFIC INSURANCE COMPANY,
DEFENDANT.

The opinion of the court was delivered by: Morrison C. England, JR United States District Judge

STIPULATION AND ORDER TO CONTINUE DISCOVERY CUT OFF ONLY

The parties, through the undersigned counsel, jointly request the Court continue the cut off 3 date for all discovery, with the exception of expert discovery, by 60 days, from June 15, 2012 to 4 August 14, 2012. The parties' request is based on the facts set forth below, which the parties 5 believe demonstrate good cause for continuance of the discovery cut off: 6

WHEREAS the parties have exchanged to date significant amounts of information and 7 documents as part of their efforts to evaluate the various claims for informal resolution; 8

WHEREAS, the parties currently have additional outstanding written discovery as well as 9 numerous depositions noticed; 10

WHEREAS the parties agree that the remaining written discovery may be sufficient to 11 enable the parties to resolve one or more claims between them informally, making the currently 12 noticed depositions, and the significant costs associated therewith, unnecessary, or at the very least 13 may assist the parties to streamline the remaining issues allowing the parties to reduce the number 14 and length of depositions, resulting in a more expeditious and economic result for all parties; 15

WHEREAS, the cut off date for all discovery, with the exception of expert discovery, is June 15, 2012, dispositive motions are to be heard by October 18, 2012, and trial is scheduled to 17 begin April 13, 2013; 18

WHEREAS, the parties are requesting a continuation of the discovery cut off date only;

WHEREAS, the parties have not previously requested a continuance of any date set by the Court's Scheduling Orders; 21

WHEREAS, the parties hereby stipulate and agree to continue the discovery cut off date 2 from June 15, 2012 to August 14, 2012. 3

Respectfully submitted, DATED: May 18, 2012 MORALES, FIERRO & REEVES By: __/s/ Laura Jane Coles_____________ Ramiro Morales Laura Jane Coles Attorneys for Plaintiffs MARYLAND CASUALTY COMPANY, STEADFAST INSURANCE COMPANY, and ASSURANCE COMPANY OF AMERICA DATED: May 18, 2012 ARCHER NORRIS 13 14 By: __/s/ Sean D. White_________________ W. Eric Blumhardt Sean D. White Attorneys for Defendant FINANCIAL PACIFIC INSURANCE COMPANY

ORDER

IT IS SO ORDERED.

20120525

© 1992-2012 VersusLaw Inc.



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