Lagunitas Brewing Company v. Sentry Equipment Erectors, Inc.

Northern District of California, cand-4:2015-cv-02971

STIPULATION AND ORDER re {{60}} Proposed Order, filed by Sentry Equipment Erectors, Inc., Charles Christopher Perkins, The Lagunitas Brewing Company, Twin City Fire Insurance Company Close of Expert Discovery due by 4/3/2017. Discovery due by 1/13/2017. Dispositive Motion to be heard by 4/14/2017. Signed by Magistrate Judge Kandis A. Westmore on 12/16/16.

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1 W. CHRISTIAN KRANKEMANN (SBN 220438) MARTIN REILLEY (SBN 83697) 2 KRANKEMANN | PETERSEN LLP Attorneys At Law 3 420 E Street, Suite 100 Santa Rosa, California 95404 4 Telephone: (707) 524-2200 Facsimile: (866) 858-0100 5 Attorney for Plaintiff 6 CHARLES CHRISTOPHER PERKINS 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 THE LAGUNITAS BREWING COMPANY, CASE NO.: 4:15-cv-02971-KAW a California Corporation; and TWIN CITY [Consolidated with Case No.: 3:15-cv-06044-KAW] KRANKEMANN | PETERSEN LLP 11 FIRE INSURANCE COMPANY, an Indiana Corporation, Telephone (707) 524-2200 | Facsimile (866) 858-0100 420 E Street, Suite 100 | Santa Rosa, California 95404 STIPULATION AND [PROPOSED] ORDER 12 Plaintiffs, EXTENDING CERTAIN DISCOVERY 13 vs. DEADLINES ATTORNEYS AT LAW 14 SENTRY EQUIPMENT ERECTORS, INC., Trial Date: June 19, 2017 a Virginia Corporation; and DOES 1 through 15 100, inclusive, 16 Defendants. 17 CHARLES CHRISTOPHER PERKINS, an individual, 18 Plaintiff, 19 vs. 20 SENTRY EQUIPMENT ERECTORS, INC., a Virginia Corporation; and DOES 1-25, 21 inclusive, Defendants. 22 23 It is hereby stipulated, by and through counsel for Plaintiff CHARLES CHRISTOPHER 24 PERKINS, Plaintiff THE LAGUNITAS BREWING COMPANY and TWIN CITY FIRE 25 INSURANCE COMPANY, and Defendant SENTRY EQUIPMENT ERECTORS, INC., that: 26 1. The parties recently attended a first attempt at Alternative Dispute Resolution (ADR) with 27 Jonathan Lee, Esq. serving as mediator on December 2, 2016. The parties believe that additional 28 non-expert discovery is needed to return to ADR in hopes of pursuing additional good faith efforts -1- STIPULATION AND [PROPOSED] ORDER EXTENDING CERTAIN DISCOVERY DEADLINES 1 to settle this case. 2 2. Many of the individuals that are to be deposed live outside of California in places such as 3 Virginia and Oregon, which makes the scheduling and attending their depositions difficult to 4 complete by December 23, 2016 as ordered by the Court and previously stipulated to the parties. 5 Some of these individuals were only identified, and their significance ascertained, during the 6 deposition of Defendant Sentry Equipment & Erectors, Inc. Rule 30(b)(6) witness, Doug Weeks, 7 that was taken on November 17, 2016 in Lynchburg, Virginia. 8 3. In an effort to resume good faith negotiations of this matter and to schedule and attend the 9 depositions in this case, the parties wish to enter into another stipulation to extend non-expert 10 discovery as well as other deadlines that could be affected by the continuance of non-expert KRANKEMANN | PETERSEN LLP 11 discovery. Telephone (707) 524-2200 | Facsimile (866) 858-0100 420 E Street, Suite 100 | Santa Rosa, California 95404 12 4. Summary of current and proposed dates: 13 Date/Deadline Current Date Proposed Date ATTORNEYS AT LAW 14 Last Day to Hear Dispositive Motions April 6, 2017 April 14, 2017 15 Close of Expert Discovery March 24, 2017 April 3, 2017 16 Rebuttal Expert Disclosure/Reports March 10, 2017 March 24, 2017 17 Defendant's Expert Disclosure/Reports February 24, 2017 March 10, 2017 18 Plaintiffs' Expert Disclosure/Reports January 20, 2017 February 10, 2017 19 Non-expert Discovery Cut-off December 23, 2016 January 13, 2017 20 ADR Completion November 30, 2016 Completed 21 22 5. The parties stipulate that all other dates in the April 29, 2016 Case Management and Pretrial 23 Order for Jury Trial can remain unchanged. 24 /// 25 /// 26 /// 27 /// 28 /// -2- STIPULATION AND [PROPOSED] ORDER EXTENDING CERTAIN DISCOVERY DEADLINES 1 IT IS SO STIPULATED. 2 DATED: December 12, 2016 KRANKEMANN | PETERSEN LLP 3 4 5 By______/s/ W. Christian Krankemann_________ W. CHRISTIAN KRANKEMANN 6 Attorney for Plaintiff, CHARLES CHRISTOPHER PERKINS 7 8 DATED: December 12, 2016 ADELSON, TESTAN, BRUNDO, NOVELL & 9 JIMENEZ 10 KRANKEMANN | PETERSEN LLP 11 By /s/ Davil Vasquez Telephone (707) 524-2200 | Facsimile (866) 858-0100 420 E Street, Suite 100 | Santa Rosa, California 95404 12 Davil Vasquez, Esq. Attorney for Plaintiffs, 13 THE LAGUNITAS BREWING COMPANY and TWIN CITY FIRE INSURANCE ATTORNEYS AT LAW 14 COMPANY 15 16 DATED: December 12, 2016 LIVINGSTON LAW FIRM 17 18 By /s/ Craig A. Livingston CRAIG A. LIVINGSTON 19 Attorney for Defendant SENTRY EQUIPMENT ERECTORS, INC. 20 21 [PROPOSED] ORDER Pursuant to the above stipulation of the parties and good cause appearing, the April 29, 22 2016 Case Management and Pretrial Order for Jury Trial is modified to reflect the Proposed 23 Dates, set forth above, AS MODIFIED. 24 25 Dated: 12/16/16 ____________________________________ 26 UNITED STATES MAGISTATE JUDGE 27 28 -3- STIPULATION AND [PROPOSED] ORDER EXTENDING CERTAIN DISCOVERY DEADLINES