2:23-cv-02687•CSAA Ins. Exchange v. Broan-NuTone LLC
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- 1 - PARTIES’ STIPULATED REQUEST TO EXTEND THE DEADLINE TO DISMISS THIS ACTION; AND ORDER THEREON 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Stephanie A. Yee (SBN 172251) Frank M. Tse (SBN 155653) Jang & Associates, LLP 2121 N. California Blvd., Suite 290 Walnut Creek, CA 94596 Telephone: (925) 937-1400 syee@janglit.com Attorneys for Plaintiff CSAA Insurance Exchange Krsto Mijanovic (Bar No. 205060) kmijanovic@hbblaw.com Steven A. Scordalakis (Bar No. 293212) sscordalakis@hbblaw.com HAIGHT BROWN & BONESTEEL LLP 555 South Flower Street, Forty-Fifth Floor Los Angeles, California 90071 Telephone: 213.542.8000 Facsimile: 213.542.8100 Attorneys for Defendant BROAN-NUTONE, LLC UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION CSAA INSURANCE EXCHANGE, as subrogee of Traci and Jason Nawahine, Plaintiffs, vs. BROAN-NUTONE LLC and DOES 1 through 50, inclusive, Defendants. Case No.: 2:23-CV-02687-DJC- CSK PARTIES’ STIPULATED REQUEST TO EXTEND THE DEADLINE TO DISMISS ACTION; AND ORDER THEREON Judge Daniel J. Calabretta Case 2:23-cv-02687-DJC-CSK Document 51 Filed 12/08/25 Page 1 of 3
- 2 - PARTIES’ STIPULATED REQUEST TO EXTEND THE DEADLINE TO DISMISS THIS ACTION; AND ORDER THEREON 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TO THE HONORABLE COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD: Plaintiff CSAA INSURANCE EXCHANGE as subrogee of Jason Nawahine and Traci Nawahine (hereinafter “CSAA”) and Defendant BROAN-NUTONE, LLC (hereinafter “Broan”) (hereinafter collectively, the “Parties”), by and through their respective counsel of record, hereby stipulate, agree, and request that this Court modify the section of Minute Order, dated October 22, 2025 (“Minute Order”), which states “the parties shall file dispositional documents within forty-five (45) days in accordance with the provisions of E.D. Cal.L.R. 160.” Good cause exists as follows: WHEREAS, on October 22, 2025, the parties gave notice to the Court that the parties had reached a settlement. WHEREAS, the Court issued the Minute Order requiring the filing of dispositional documents by December 8, 2025. WHEREAS, it has taken longer than anticipated for the parties to agree upon non-monetary terms of the settlement agreement. WHEREAS, the parties have agreed to all terms of the settlement and are in the process of completing the settlement terms. WHEREAS, this is the first request to modify the Minute Order. WHEREAS, the parties anticipate that it will take an additional 30 days to complete the settlement terms. THEREFORE, the parties stipulate and agree, and hereby request, that this Court extend the deadline for the parties to file dispositional documents to January 9, 2026. IT IS SO STIPULATED. /// /// Case 2:23-cv-02687-DJC-CSK Document 51 Filed 12/08/25 Page 2 of 3
- 3 - PARTIES’ STIPULATED REQUEST TO EXTEND THE DEADLINE TO DISMISS THIS ACTION; AND ORDER THEREON 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: December 5, 2025 JANG & ASSOCIATES, LLP By:/s/ Stephanie A. Yee Stephanie A. Yee Attorneys for Plaintiff CSAA INSURANCE EXCHANGE Dated: December 5, 2025 HAIGHT BROWN & BONESTEEL LLP By:/s/Steven A. Scordalakis Steven A. Scordalakis Attorneys for Defendant BROAN-NUTONE LLC PROPOSED ORDER PURSUANT TO THE PARTIES’ STIPULATION, AND GOOD CAUSE HAVING BEEN SHOWN, this Court hereby orders as follows: The parties shall file dispositional documents in accordance with the provisions of E.D. Cal.L.R. 160 on or before January 9, 2026. PURSUANT TO STIPULATION, IT IS SO ORDERED. Dated: December 5, 2025 /s/ Daniel J. Calabretta THE HONORABLE DANIEL J. CALABRETTA UNITED STATES DISTRICT JUDGE Case 2:23-cv-02687-DJC-CSK Document 51 Filed 12/08/25 Page 3 of 3
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