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Logan v. Patriot National, Inc.

United States District Court, E.D. California

April 24, 2017

Tammy Lynn Logan, an individual, Plaintiff,
v.
Patriot National, Inc., a Delaware Corporation; Patriot Risk Services, Inc., a Delaware Corporation; Patriot Claim Services, Inc., a Delaware Corporation; Patriot Risk Management, Inc., a Delaware Corporation; and Does 1 through 50, inclusive, Defendants.

          Date Filed: April 22, 2016

          ARIAS SANGUINETTI STAHLE & TORRIJOS, LLP Alfredo Torrijos Mike Arias, Esq. Alfredo Torrij os, Esq. Attorneys for Plaintiff Tammy Lynn Logan

          LITTLER MENDELSON JoAnna L. Brooks, Esq. Britney N. Torres, Esq., Attorneys for Defendant Patriot National, Inc., Patriot Risk Services, Inc., Patriot Claim Services, Inc., and Patriot Risk Consultants, Inc.

          JOINT STIPULATION AND ORDER EXTENDING DISCOVERY DEADLINES

          MORRISON C. ENGLAND UNITED STATES DISTRICT JUDGE

         Pursuant to Local Rule 143 and the Court's June 22, 2016 Initial Pretrial Scheduling Order (Dkt. #2), 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 Court's June 22, 2016 Initial Pretrial Scheduling Order set, inter alia, the following deadlines:

Event

Date

Fact Discovery

April 21, 2017

Initial Expert Disclosures

June 20, 2017

Rebuttal Expert Disclosures

July 20, 2017

Dispositive Motion Filing Deadline

October 18, 2017

Notice of Trial Readiness

30 days after receiving Court's ruling on the last field dispositive motions

         WHEREAS, Plaintiff has noticed the deposition of a number of Defendants' employees who are located out-of-state and are not available prior to the fact discovery deadline;

         WHEREAS, the parties require additional time to complete depositions and engage in other discovery after the depositions, if necessary;

         WHEREAS, no trial date has been set for this case;

         WHEREAS, the proposed extension to the discovery and expert disclosure deadlines will not impact the trial date of this case ...


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