Warkentin v. Federated Life Insurance Company
Filing
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STIPULATION and ORDER re Modification of Scheduling Order: Discovery Deadlines - Non Expert 12/15/2011; Expert 12/20/2011; Dispositive Motions filed by 12/7/2011; Hearing 1/16/2012; Non-Dispositive Motions filed by 1/13/2012; Hearing 2/6/2012; Pretri al Conference set for 3/23/2012 at 01:30 PM in Courtroom 9 (DLB) before Magistrate Judge Dennis L. Beck; Jury Trial set for 5/15/2012 at 09:00 AM in Courtroom 9 (DLB) before Magistrate Judge Dennis L. Beck. Order signed by Magistrate Judge Dennis L. Beck on 8/2/2011. (Hernandez, M)
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THE COSTA LAW FIRM
DANIEL P. COSTA, State Bar No. 110919
2489 Sunrise Blvd., Suite A
Gold River, California 95670
Telephone: (916) 400-2734
Telecopier: (916) 400-2744
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Attorneys for Defendant
FEDERATED LIFE INSURANCE COMPANY
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IN THE UNITED STATES DISTRICT COURT
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FOR THE EASTERN DISTRICT OF CALIFORNIA
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KEITH WARKENTIN,
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Plaintiff,
vs.
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FEDERATED LIFE INSURANCE COMPANY;
a Minnesota Corporation registered to do
business in California; and DOES 1 to 60,
Defendants.
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CASE NO: 1:10-CV-00221-DLB
STIPULATION AND PROPOSED ORDER
RE: MODIFICATION OF SCHEDULING
ORDER
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COMES NOW the parties through their respective counsel of record and hereby STIPULATE
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AND AGREE that the current Scheduling Order be modified to allow the parties to complete
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discovery, file dispositive motions, if necessary, and participate in a meaningful Settlement
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Conference. These modifications are necessary due to the fact that a number of out-of-state
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depositions have to be completed, counsel for FEDERATED was engaged in a lengthy Trial and
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Binding Arbitrations affecting the scheduling of certain depositions, and Plaintiff recently underwent
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a back surgery. As such, the parties are requesting that all dates be extended for a period of
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approximately 90 days as follows:
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STIPULATION AND PROPOSED ORDER RE: MODIFICATION OF SCHEDULING ORDER
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Discovery Deadlines:
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Present date
New date
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Non-expert:
September 14, 2011
December 15, 2011
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Expert:
September 19, 2011
December 20, 2011
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2.
Non-Dispositive Motion Deadlines:
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Present date
New date
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Filing:
October 11, 2011
January 13, 2012
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Hearing:
November 4, 2011
February 6, 2012
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Dispositive Motion Deadlines:
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Present date
New date
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Filing:
September 6, 2011
December 7, 2011
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Hearing:
October 14, 2011
January 16, 2012
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Settlement Conference: June 8, 2011 (taken off calendar) - New date: TBA
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5.
Pre-Trial Conference:
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Present date
New date
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December 16, 2011
@ 1:30 p.m., Courtroom 9
March 23, 2012
Present date
New date
February 7, 2012
May 15, 2012
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Jury Trial:
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DATED: August 2, 2011
THE COSTA LAW FIRM
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By:
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/S/ DANIEL P. COSTA
DANIEL P. COSTA
Attorneys for Defendant
FEDERATED LIFE INSURANCE COMPANY
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STIPULATION AND PROPOSED ORDER RE: MODIFICATION OF SCHEDULING ORDER
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DATED: August 2, 2011
HOLLINGSWORTH LAW FIRM
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By:
/S/ DAVID HOLLINGSWORTH
DAVID HOLLINGSWORTH
Attorneys for Plaintiff
KEITH WARKENTIN
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ORDER
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GOOD CAUSE APPEARING,
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IT IS SO ORDERED.
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Dated:
August 2, 2011
/s/ Dennis L. Beck
UNITED STATES MAGISTRATE JUDGE
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STIPULATION AND PROPOSED ORDER RE: MODIFICATION OF SCHEDULING ORDER
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