Opinion
2:20-cv-00790-JAD-NJK
04-10-2023
UNITED STATES OF AMERICA, for the use and benefit of SUSTAINABLE MODULAR MANAGEMENT, INC., a Texas corporation Plaintiff, v. JE DUNN CONSTRUCTION COMPANY FEDERAL INSURANCE COMPANY; HARTFORD FIRE INSURANCE COMPANY; TRAVELERS CASUALTY AND SURETY COMPANY OF AMERICA; DOE Individuals I-X and ROE Entities I-X, inclusive, Defendant
MORRIS LAW GROUP Steve Morris, Bar Rosa Solis-Rainey Michael S. Alfred (pro hac vice) VerisLaw, PLLC Attorneys for Plaintiff LEWIS ROCA ROTHGERBER CHRISTIE LLP Adrienne Brantley-Lomeli, Attorneys for Defendant JE Dunn Construction Company
MORRIS LAW GROUP Steve Morris, Bar Rosa Solis-Rainey
Michael S. Alfred (pro hac vice) VerisLaw, PLLC Attorneys for Plaintiff
LEWIS ROCA ROTHGERBER CHRISTIE LLP Adrienne Brantley-Lomeli, Attorneys for Defendant JE Dunn Construction Company
JOINT STIPULATION REGARDING DEPOSITION SCHEDULE
Consistent with this Court's Order [Dkt. 95] regarding the Renewed Joint Stipulation and Order to Extend Discovery and Related Deadlines [Dkt.94], the Parties submit this Joint Stipulation Regarding Deposition Schedule. This stipulation is made by and between all parties to this consolidated action (United States of America, for the use and benefit of Sustainable Modular Management, Inc. (“SMM”); JE Dunn Construction Company (“JE Dunn”); Harford Fire Insurance Company (“Hartford”); Travelers Casualty and Surety Company of America (“Travelers”); Federal Insurance Company (“Federal”); and Pacific Indemnity Company (“Pacific”) through their respective counsel (collectively, the “Parties.”).
Sustainable Modular Management plans to notice this deposition. The Assistant United States Attorney handling the scheduling of this deposition has not yet provided available dates for this deposition. Because this deposition involves a non-party, Government witness, SMM and JE Dunn have agreed to cooperate in setting this deposition once the Government provides available dates.
1. The schedule for completing all remaining depositions is as follows:
Deponent
Date
Location
Eli Kaldahl
April 18, 2023
Kansas City, Missouri
Craig Stearns
April 20, 2023
Kansas City, Missouri
Neal Gaudion
April 25, 2023
Phoenix, Arizona
Jeramy Bristol (Begin am)/ Rick Bartolotti (Begin pm)/
April 26, 2023
Phoenix, Arizona
Joe Waters (am)
April 27, 2023
Phoenix, Arizona
Kevin Purvis
May 8, 2023
Dallas, Texas
Kevin Finn
May 9, 2023
Dallas, Texas
Barry Bray
May 11, 2023
Zoom
Nick Mackie
May 17, 2023
Dallas, Texas
Bill Schwartzkopf
May 31, 2023
Denver, Colorado
Army Corps of Engineers Representative
Floating as nonparty witness
Little Rock, Arkansas (anticipated)
STIPULATION
NOW, THEREFORE, the Parties hereby stipulate and agree to the Deposition Schedule as described herein.
With respect to the deposition of the Army Corp of Engineers, Sustainable Modular Management must promptly provide the assigned AUSA with a copy of the order at Docket No. 95. A stipulation with a firm deposition date for the Army Court of Engineers must be filed by April 24, 2023.
Order
IT IS SO ORDERED.