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National Frozen Foods Corp. v. Berkley Assurance Co.

United States District Court, W.D. Washington, Seattle

July 23, 2018

NATIONAL FROZEN FOODS CORPORATION, a Washington corporation, Plaintiff,
v.
BERKLEY ASSURANCE COMPANY, an Iowa corporation; AMWINS BROKERAGE OF ILLINOIS, a North Carolina Limited Liability Company; AMWINS BROKERAGE OF ARIZONA, a Delaware Limited Liability Company; and AMWINS GROUP LLC, a Delaware Limited Liability Company, Defendants. Event Current Deadline New Deadline Event Current Deadline New Deadline

          Attorneys for Plaintiff National Frozen Foods Corp. Brendan Winslow-Nason, Dale L. Kingman,

          Attorneys for Defendant Berkley Assurance Company Justin S. Landreth, Peter J. Mintzer,

          Attorneys for Defendant Berkley Assurance Co. Jeffrey S. Weinstein

          Attorneys for AmWins Defendants Alison L. Markette, Stephen G. Skinner,

          STIPULATED MOTION AND ORDER AMENDING DISCOVERY DEADLINES

          RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE

         STIPULATION

         The parties, by and through their counsel of record, hereby stipulate and agree to this joint request to the Court to amend certain discovery deadlines contained in the Order Amending Order Setting Trial Date and Related Dates (Dkt. 53). The reasons justifying the proposed amendment are as follows:

         • Severe weather on the East Coast forced the cancellation of the 30(b)(6) and individual depositions of Berkley Assurance Corporation that were scheduled to take place in New York the week of July 16. The earliest dates that these depositions can be rescheduled is for the week of September 3, which is after the current expert disclosure / report deadline; and

         • Scheduling issues have arisen with several other fact witness depositions that necessitate an amendment to the current case schedule in order to allow sufficient time to complete expert discovery. The parties therefore stipulate and agree that the case schedule deadlines should be amended as follows:

         Event Current Deadline New Deadline Expert Witness Disclosure/Reports under FRCP August 8, 2018 September 19, 2018 26(a)(2) [Moved to August 22, 2018 pursuant to prior stipulation]

         Discovery Motions September 10, 2018 October 3, 2018 Expert Rebuttal Reports September 21, October 10, 2018[1]

         Discovery Completed By October 8, 2018 October 29, 2018 All other case schedule deadlines will remain the same.

Event
Current Deadline
New Deadline

Expert Witness Disclosure/Reports under FRCP 26(a)(2)

August 8, 2018 [Moved to August 22, 2018 pursuant to prior stipulation]

September 19, 2018

Discovery Motions

September 10, 2018

October 3, 2018

Expert Rebuttal Reports

September 21, 2018

October 10, 2018

Discovery Completed By

October 8, 2018

October 29, 2018


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