Opinion
Case No. 2:11-CV-00346-MCE-JFM
10-26-2011
SIERRA PACIFIC INDUSTRIES, Plaintiff, v. AMERICAN STATES INSURANCE COMPANY, Defendant.
SHEPPARD MULLIN RICHTER & HAMPTON LLP LEO D. CASERIA Attorneys for Defendant AMERICAN STATES INSURANCE COMPANY THE LAW OFFICE OF DENISE JARMAN Denise Jarman (as authorized on October 17, 2011) DENISE JARMAN Attorneys for Plaintiff SIERRA PACIFIC INDUSTRIES, INC.
FRANK FALZETTA, Cal. Bar No. 125146
SCOTT SVESLOSKY, Cal. Bar No. 217660
LEO D. CASERIA, Cal. Bar No. 240323
SHEPPARD MULLIN RICHTER & HAMPTON LLP
Attorneys for Defendant
AMERICAN STATES INSURANCE
COMPANY
STIPULATION AND ORDER
EXTENDING TIME FOR PARTIES
TO RESPOND TO DISCOVERY
STIPULATION
WHEREAS, defendant American States Insurance Company ("ASIC") served plaintiff Sierra Pacific Industries, Inc. ("SPI") with its First Set of Interrogatories and First Demand for Production of Documents by regular mail on August 1, 2011;
WHEREAS, SPI served ASIC with SPI's Demand For Production Of Documents To Defendant ASIC, Set One by regular mail on August 23, 2011;
WHEREAS, SPI and ASIC have both obtained one 28-day extension to respond to the discovery requests that are the subject of this Joint Application, extending the time for SPI to respond to ASIC's First Set of Interrogatories and First Demand for Production of Documents until October 4, 2011 (see Docket Entry # 22) and extending the time for ASIC to respond to SPI's Document Demands until October 24, 2011 (see Docket Entry #23);
WHEREAS, on October 4, 2011, the deadline for SPI to respond to ASIC's First Set of Interrogatories and First Demand for Production of Documents, SPI served ASIC with written responses and objections but no documents;
WHEREAS, the parties have met and conferred and have agreed to cooperate and work together on a stipulated protective order to facilitate the production of documents and responses to written discovery;
WHEREAS, Local Rule 144(a) of the United States District Court, Eastern District of California provides that an initial 28-day extension of time to respond to discovery does not require Court approval, but "[a]ll other extensions of time must be approved by the Court";
NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties, through their undersigned counsel, that:
1. SPI and ASIC shall work diligently on a stipulated protective order to facilitate the production of documents and information responsive to the parties' respective discovery requests;
2. Within 30 days of the Court's entry of a protective order, SPI will produce documents and provide information to ASIC in response to ASIC's First Set of Interrogatories and First Demand for Production of Documents;
3. Also within 30 days of the Court's entry of a protective order, ASIC will respond to SPI's Demand For Production Of Documents;
4. SPI and ASIC must bring motions to compel further responses and supplemental production, if any, within 60 days of the deadlines set forth in paragraphs 2 and 3 above.
SHEPPARD MULLIN RICHTER & HAMPTON LLP
LEO D. CASERIA
Attorneys for Defendant
AMERICAN STATES INSURANCE COMPANY
THE LAW OFFICE OF DENISE JARMAN
Denise Jarman (as authorized on
October 17, 2011)
DENISE JARMAN
Attorneys for Plaintiff
SIERRA PACIFIC INDUSTRIES, INC.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
MORRISON C. ENGLAND, JR
UNITED STATES DISTRICT JUDGE