Opinion
2:22-cv-00879-JCM-EJY
12-20-2022
FREDDY HWANG, an Individual; SAPPORO GROUP NEVADA, INC., a Domestic Corporation; PLAINTIFFS, v. REDWOOD FIRE & CASUALTY INSURANCE COMPANY, a Foreign Corporation DOES 1 through 25, inclusive; and ROE CORPORATIONS 1 through 25, inclusive, DEFENDANTS.
PATRICK W. KANG, ESQ. KYLE R. TATUM, ESQ. PAUL H. WOLFRAM, ESQ. KANG & ASSOCIATES, PLLC Attorneys for Plaintiffs FREDDY HWANG MICHAEL W. MELENDEZ, ESQ. COZEN O'CONNOR Attorneys for Defendant REDWOOD FIRE & CASUALTY INSURANCE COMPANY
PATRICK W. KANG, ESQ.
KYLE R. TATUM, ESQ.
PAUL H. WOLFRAM, ESQ.
KANG & ASSOCIATES, PLLC
Attorneys for Plaintiffs
FREDDY HWANG
MICHAEL W. MELENDEZ, ESQ.
COZEN O'CONNOR
Attorneys for Defendant
REDWOOD FIRE & CASUALTY INSURANCE COMPANY
STIPULATION AND ORDER TO EXTEND DISCOVERY DEADLINES (SECOND REQUEST)
IT IS HEREBY STIPULATED by and between Plaintiffs, FREDDY HWANG, an Individual, SAPPORO GROUP NEVADA, INC., a Domestic Corporation and Defendants, REDWOOD FIRE & CASUALTY INSURANCE COMPANY, a Foreign Corporation, by their respective counsel, pursuant to EDCR 2.35 as follows:
Discovery Completed
1. Plaintiff has tendered Initial Disclosures and multiple supplements thereto;
2. Plaintiff has served written discovery requests to Defendant including requests for admissions, requests for production of documents, and interrogatories;
3. Defendant has tendered Initial Disclosures;
4. Defendant has served written discovery requests to Defendant including requests for admissions, requests for production of documents, and interrogatories;
5. Plaintiff has responded to Defendant's written discovery requests;
6. Defendant has responded to Plaintiff's written discovery requests;
7. Plaintiff has provided his expert disclosures;
8. Defendant has provided its expert disclosures; and
9. Both parties have noticed the depositions of a number of witnesses and parties.
Discovery to be Completed
1. Deposition of the parties, including Defendant's FRCP 30(b)(6) Witness;
2. Depositions of any and all experts disclosed by the parties;
3. Depositions of additional fact witnesses; and
4. All other discovery that may become necessary as litigation continues.
The Parties Have Agreed to Extend Discovery
The parties have acted in good faith in attempting to comply with discovery deadlines. As the parties have attempted to complete necessary discovery there have been some delays in coordinating the depositions of a number of witnesses in order to accommodate the schedules of the deponents and counsel. The parties are amicably working towards a resolution to ensure that all depositions move forward in a manner that is satisfactory for all parties. Therefore, the parties have agreed for a need to briefly extend the discovery deadlines in order to come to a resolution and accommodate the availability of the remaining depositions.
Therefore, the parties seek a 60-day extension in order to carry out remaining discovery. Counsel is in no way attempting to delay discovery in this matter, as they have been working to complete discovery in good faith.
PROPOSED SCHEDULE OF DISCOVERY
The parties hereby stipulate to continue the Discovery as follows:
Current Deadline
Proposed
Discovery Deadline:
December 30, 2022
February 28, 2023
Dispositive Motions:
December 30, 2022
March 30, 2023
Joint Pre-Trial Order:
January 30, 2023
May 1, 2023
Current Trial Date
No trial dates have been set at this time.
IT IS SO ORDERED.