Opinion
Case No. 2:11-CV-00934-MCE-AC
05-08-2013
UNIVERSAL CASUALTY COMPANY, Plaintiff, v. FRED C. GODINEZ, III, YOGESH KUMAR, LINKS INSURANCE SERVICES, INC., and NATIONAL TRANSPORTATION ASSOCIATES, INC. D/B/A NTA GENERAL INSURANCE AGENCY, INC., Defendants.
UNIVERSAL CASUALTY COMPANY Alex Darcy, Esq. (ARDC# 189315) ASKOUNIS & DARCY, P.C. MORRIS & STONE, LLP Aaron P. Morris, Esq. (SBN #130727) MORRIS & STONE, LLP
Alex Darcy (CSBA No. 189315)
Askounis & Darcy, PC
444 N. Michigan Ave., Suite 3270
Chicago, Illinois 60611
Tel: (312) 784-2400
Fax: (312) 784-2410
adarcy@askounisdarcy.com
Attorney for Plaintiff
UNIVERSAL CASUALTY COMPANY
Chief Judge Morrison C. England, Jr.
Magistrate Judge Allison Claire
JOINT STIPULATION TO CONTINUE
HEARING ON PLAINTIFF'S
MOTION TO COMPEL
AND ORDER THEREON
Complaint Filed: April 7, 2011
Trial Date: May 19, 2014, 9:00 a.m. PST
TO THE COURT:
The Parties to the Motion to Compel, Plaintiff Universal Casualty Company ("Universal," "UCC" or "Plaintiff") and Defendants Yogesh Kumar ("Kumar"), Links Insurance Services, Inc. ("Links"), National Transportation Associates, Inc. d/b/a NTA General Insurance Agency, Inc. ("NTA") (collectively, the "Discovery Defendants"), by and through their counsel of record, hereby stipulate that the hearing on the Motion to Compel be continued until May 15, 2013, 10:00 am PST, based on the following:
1. It is UCC's understanding that the Parties have reached an Agreement regarding all deficiencies relating to the Discovery Requests directed to the Discovery Defendants and that UCC would receive all outstanding responses and document productions (aside from the Settlement Agreement with Crusader Insurance Company which Links and Kumar agreed to produce upon this Court's Order) by April 29, 2013.
2. On the evening on April 23, 2013, UCC received an e-mail from the counsel for the Discovering Defendants which contained access via Dropbox to what was represented to be document production for NTA, Links, (but not Kumar), which consists of approximately 5,500 pages of documents. Kumar's outstanding discovery responses are due by April 29, 2013.
3. Due to the voluminous nature of this recent document production, UCC would like to ask this Court to continue the May 1, 2013 hearing on the Motion to Compel to May 15, 2013, so that UCC can review the documents that have just been produced and the documents due early next week, and subsequently confer with the Discovering Defendants regarding any deficiencies. The Discovery Defendants do not object to this continuance.
4. To the extent that any of the deficiencies are cured, UCC will be withdrawing its Motion to Compel relating to those deficiencies.
5. Counsel for the Discovering Defendants has reviewed and approved the wording of this stipulation and have authorized UCC's counsel to submit this stipulation on their behalf.
SO STIPULATED.
UNIVERSAL CASUALTY COMPANY
By: __________________________
Alex Darcy, Esq. (ARDC# 189315)
ASKOUNIS & DARCY, P.C.
MORRIS & STONE, LLP
By: __________________________
Aaron P. Morris, Esq. (SBN #130727)
MORRIS & STONE, LLP
IT IS SO ORDERED
__________________________
ALLISON CLAIRE
United States Magistrate Judge