Joint MOTION for Extension of Time to Complete Discovery and Entry of Stipulated Revised Scheduling Order by AMERICAN GUARANTEE AND LIABILITY INSURANCE COMPANY, BAPTISTE & WILDER, P.C., ROBERT M. BAPTISTE, PATRICK J. SZYMANSKI. (Attachments: # (1))(Karpinski, Richard)
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Page 1 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRIC OF COLUMBIA
AMERICAN GUARANTEE AND
LIABILITY INSURANCE COMPANY
Plaintiff,
v.
BAPTISTE & WILDER, P.C., et al.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
CASE NO.: 05-01958
JOINT STIPULATED MOTION FOR ENLARGEMENT OF TIME
AND ENTRY OF STIPULATED REVISED SCHEDULING ORDER
Plaintiff, American Guarantee and Liability Insurance Company (“AGLI”) and
Defendants, Baptiste & Wilder, P.C., Robert M. Baptiste, and Patrick J. Szymanski,
hereby move, jointly and by stipulation, pursuant to Fed. R. Civ. P. 1, 16, and 23, and
Local Rules 7, 16.1 and 16.4 of the Local Rules of this Court, for an enlargement of time
to complete discovery, and for entry of the accompanying stipulated Revised
Scheduling Order.
The grounds for this Motion are set forth in the accompanying Memorandum of
Points and Authorities. As discussed therein, the Parties are actively engaged in
discovery in this case, and respectfully request that the Court extend the close of
discovery to November 30, 2006, with a corresponding extension of other deadlines, to
permit the parties to complete their ongoing discovery in an orderly manner. An
independent reason to extend the discovery period in this case is that a mediation is in
the process of being scheduled in the underlying (non-coverage) litigation pending inPage 2 the Superior Court of the District of Columbia. The Parties are hopeful that this
mediation may permit a resolution not only of that case but of this one as well.
A stipulated proposed Order is submitted herewith.
Dated: July 11, 2006
Respectfully submitted,
/s/
William J. Carter, 329637
CARR MALONEY P.C.
1615 L Street, N.W.
Suite 500
Washington, DC 20036
(202) 310-5500 (telephone)
(202) 310-5555 (facsimile)
/s/
Judah Lifschitz, Esq., 963330
Richard Karpinski, Esq., 393412
SHAPIRO, LIFSCHITZ AND SCHRAM, P.C.
1742 N Street, N.W.
Washington, D.C. 20036
(202) 689-1900 (telephone)
(202) 689-1901 (facsimile)
Counsel for American Guarantee and
Liability insurance Company
Counsel for Defendants Baptiste & Wilder,
P.C., Robert M. Baptiste & Patrick J.
Szymanski
2Page 3 IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRIC OF COLUMBIA
AMERICAN GUARANTEE AND
LIABILITY INSURANCE COMPANY
Plaintiff,
v.
BAPTISTE & WILDER, P.C., et al.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
CASE NO.: 05-01958
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
JOINT STIPULATED MOTION FOR ENLARGEMENT OF TIME
AND ENTRY OF STIPULATED REVISED SCHEDULING ORDER
Plaintiff, American Guarantee and Liability Insurance Company (“AGLI”) and
Defendants, Baptiste & Wilder, P.C., Robert M. Baptiste, and Patrick J. Szymanski,
move, jointly and by stipulation, pursuant to Fed. R. Civ. P. 1, 16, and 23, and Local
Rules 7, 16.1 and 16.4 of the Local Rules of this Court, for an enlargement of time to
complete discovery, and for entry of the accompanying stipulated Revised Scheduling
Order.
The present scheduling order provides for discovery to close on July 31, 2006,
with dispositive motions on August 31, 2006, responses 30 days thereafter, replies 15
days after responses, and a pretrial conference thereafter at the Court’s convenience to,
among other things, set a trial date.
The Parties respectfully request that the close of discovery be extended to
November 30, 2006, with a corresponding extension of the other deadlines in the case,
to permit the parties time to conclude their ongoing discovery in an orderly fashion. An
independent reason to extend the discovery period in this case is that a mediation is inPage 4 the process of being scheduled in the underlying (non-coverage) litigation pending in
the Superior Court of the District of Columbia. The Parties are hopeful that this
mediation may permit a resolution not only of that case but of this one as well.
The Parties are pleased to report that they have completed the exchange of, and
response to, interrogatories and requests for production of documents. The Parties are
reviewing these responses and anticipate possible requests for supplementation in
various areas. In the interim, the 30(b)(6) deposition of the Plaintiff is scheduled for July
18, 2006, and that of defendant Patrick Szymanski for July 19, 2006. The Parties are
working cooperatively to schedule the remaining depositions in the case. These are
expected to include the deposition of defendant Robert M. Baptiste, as well as the
depositions of the three expert witnesses (one for Plaintiff and two for Defendants)
named in the case. Based on discussions to date, it appears likely that Defendants will
also request additional 30(b)(6) depositions of Plaintiffs after the first, to cover certain
areas that the first witness may not be able to fully discuss. Various of counsel also
have extensive deposition and related calendars in other matters during the months of
July, August and September, including an upcoming trial in a complex commercial
arbitration and extensive depositions in a matter pending in the United States District
Court for the District of Maryland.
CONCLUSION
For the foregoing reasons, the Parties’ motion should be granted.
2Page 5 Dated: July 11, 2006
Respectfully submitted,
/s/
William J. Carter, 329637
CARR MALONEY P.C.
1615 L Street, N.W.
Suite 500
Washington, DC 20036
(202) 310-5500 (telephone)
(202) 310-5555 (facsimile)
/s/
Judah Lifschitz, Esq., 963330
Richard Karpinski, Esq., 393412
SHAPIRO, LIFSCHITZ AND SCHRAM, P.C.
1742 N Street, N.W.
Washington, D.C. 20036
(202) 689-1900 (telephone)
(202) 689-1901 (facsimile)
Counsel for American Guarantee and
Liability insurance Company
Counsel for Defendants Baptiste & Wilder,
P.C., Robert M. Baptiste & Patrick J.
Szymanski
3
PDF Page 1
PlainSite Cover Page
PDF Page 2
Case 1:05-cv-01958-JR
Document 15
Filed 07/11/2006
Page 1 of 5
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRIC OF COLUMBIA
AMERICAN GUARANTEE AND
LIABILITY INSURANCE COMPANY
Plaintiff,
v.
BAPTISTE & WILDER, P.C., et al.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
CASE NO.: 05-01958
JOINT STIPULATED MOTION FOR ENLARGEMENT OF TIME
AND ENTRY OF STIPULATED REVISED SCHEDULING ORDER
Plaintiff, American Guarantee and Liability Insurance Company (“AGLI”) and
Defendants, Baptiste & Wilder, P.C., Robert M. Baptiste, and Patrick J. Szymanski,
hereby move, jointly and by stipulation, pursuant to Fed. R. Civ. P. 1, 16, and 23, and
Local Rules 7, 16.1 and 16.4 of the Local Rules of this Court, for an enlargement of time
to complete discovery, and for entry of the accompanying stipulated Revised
Scheduling Order.
The grounds for this Motion are set forth in the accompanying Memorandum of
Points and Authorities. As discussed therein, the Parties are actively engaged in
discovery in this case, and respectfully request that the Court extend the close of
discovery to November 30, 2006, with a corresponding extension of other deadlines, to
permit the parties to complete their ongoing discovery in an orderly manner. An
independent reason to extend the discovery period in this case is that a mediation is in
the process of being scheduled in the underlying (non-coverage) litigation pending in
PDF Page 3
Case 1:05-cv-01958-JR
Document 15
Filed 07/11/2006
Page 2 of 5
the Superior Court of the District of Columbia. The Parties are hopeful that this
mediation may permit a resolution not only of that case but of this one as well.
A stipulated proposed Order is submitted herewith.
Dated: July 11, 2006
Respectfully submitted,
/s/
William J. Carter, 329637
CARR MALONEY P.C.
1615 L Street, N.W.
Suite 500
Washington, DC 20036
(202) 310-5500 (telephone)
(202) 310-5555 (facsimile)
/s/
Judah Lifschitz, Esq., 963330
Richard Karpinski, Esq., 393412
SHAPIRO, LIFSCHITZ AND SCHRAM, P.C.
1742 N Street, N.W.
Washington, D.C. 20036
(202) 689-1900 (telephone)
(202) 689-1901 (facsimile)
Counsel for American Guarantee and
Liability insurance Company
Counsel for Defendants Baptiste & Wilder,
P.C., Robert M. Baptiste & Patrick J.
Szymanski
2
PDF Page 4
Case 1:05-cv-01958-JR
Document 15
Filed 07/11/2006
Page 3 of 5
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRIC OF COLUMBIA
AMERICAN GUARANTEE AND
LIABILITY INSURANCE COMPANY
Plaintiff,
v.
BAPTISTE & WILDER, P.C., et al.,
Defendants.
)
)
)
)
)
)
)
)
)
)
)
CASE NO.: 05-01958
MEMORANDUM OF POINTS AND AUTHORITIES IN SUPPORT OF
JOINT STIPULATED MOTION FOR ENLARGEMENT OF TIME
AND ENTRY OF STIPULATED REVISED SCHEDULING ORDER
Plaintiff, American Guarantee and Liability Insurance Company (“AGLI”) and
Defendants, Baptiste & Wilder, P.C., Robert M. Baptiste, and Patrick J. Szymanski,
move, jointly and by stipulation, pursuant to Fed. R. Civ. P. 1, 16, and 23, and Local
Rules 7, 16.1 and 16.4 of the Local Rules of this Court, for an enlargement of time to
complete discovery, and for entry of the accompanying stipulated Revised Scheduling
Order.
The present scheduling order provides for discovery to close on July 31, 2006,
with dispositive motions on August 31, 2006, responses 30 days thereafter, replies 15
days after responses, and a pretrial conference thereafter at the Court’s convenience to,
among other things, set a trial date.
The Parties respectfully request that the close of discovery be extended to
November 30, 2006, with a corresponding extension of the other deadlines in the case,
to permit the parties time to conclude their ongoing discovery in an orderly fashion. An
independent reason to extend the discovery period in this case is that a mediation is in
PDF Page 5
Case 1:05-cv-01958-JR
Document 15
Filed 07/11/2006
Page 4 of 5
the process of being scheduled in the underlying (non-coverage) litigation pending in
the Superior Court of the District of Columbia. The Parties are hopeful that this
mediation may permit a resolution not only of that case but of this one as well.
The Parties are pleased to report that they have completed the exchange of, and
response to, interrogatories and requests for production of documents. The Parties are
reviewing these responses and anticipate possible requests for supplementation in
various areas. In the interim, the 30(b)(6) deposition of the Plaintiff is scheduled for July
18, 2006, and that of defendant Patrick Szymanski for July 19, 2006. The Parties are
working cooperatively to schedule the remaining depositions in the case. These are
expected to include the deposition of defendant Robert M. Baptiste, as well as the
depositions of the three expert witnesses (one for Plaintiff and two for Defendants)
named in the case. Based on discussions to date, it appears likely that Defendants will
also request additional 30(b)(6) depositions of Plaintiffs after the first, to cover certain
areas that the first witness may not be able to fully discuss. Various of counsel also
have extensive deposition and related calendars in other matters during the months of
July, August and September, including an upcoming trial in a complex commercial
arbitration and extensive depositions in a matter pending in the United States District
Court for the District of Maryland.
CONCLUSION
For the foregoing reasons, the Parties’ motion should be granted.
2
PDF Page 6
Case 1:05-cv-01958-JR
Document 15
Filed 07/11/2006
Page 5 of 5
Dated: July 11, 2006
Respectfully submitted,
/s/
William J. Carter, 329637
CARR MALONEY P.C.
1615 L Street, N.W.
Suite 500
Washington, DC 20036
(202) 310-5500 (telephone)
(202) 310-5555 (facsimile)
/s/
Judah Lifschitz, Esq., 963330
Richard Karpinski, Esq., 393412
SHAPIRO, LIFSCHITZ AND SCHRAM, P.C.
1742 N Street, N.W.
Washington, D.C. 20036
(202) 689-1900 (telephone)
(202) 689-1901 (facsimile)
Counsel for American Guarantee and
Liability insurance Company
Counsel for Defendants Baptiste & Wilder,
P.C., Robert M. Baptiste & Patrick J.
Szymanski
3
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