Honnevk et al v. Farmers New World Life Insurance Company

Filing 13

STIPULATION and ORDER GRANTING an extension of the following pretrial deadlines: Designation of Expert Witnesses due by 11/2/2012; Non-Expert Discovery deadline is 11/2/2012; Expert Discovery deadline is 11/30/2012; order signed by Magistrate Judge Dennis L. Beck on 10/9/2012. (Rooney, M)

1 William D. Naeve (SBN 92270)
MURCHISON & CUMMING, LLP
2 200 West Santa Ana Boulevard, Suite 801
Santa Ana, California 92701-4134
3 Telephone: [phone]
Facsimile: [phone]
4 [e-mail]
5 Attorneys for Defendant, FARMERS NEW
WORLD LIFE INSURANCE COMPANY
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7 Timothy L. Marks
TIMOTHY L. MARKS & ASSOCIATES
8 4753 East Olive Avenue, Suite 103
Fresno, CA 93702
9 Telephone: [phone]
Facsimile: [phone]
10 [e-mail]
11 Attorney Plaintiffs, FRISCO HONNEVK and
BOUALAI VONGPHACHANH
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION

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FRISCO HONNEVK, BOUALAI
17 VONGPHACHANH,
Plaintiffs,

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CASE NO. 1:11 CV 01531 AWI DLB
STIPULATION TO EXTEND
DISCOVERY CUT OFF

vs.
Trial Date:

March 13, 2013

20 FARMERS NEW WORLD LIFE
INSURANCE COMPANY,
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Defendant.
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TO THE CLERK OF THE ABOVE ENTITLED COURT AND TO THE
PARTIES AND TO THEIR RESPECTIVE ATTORNEYS OF RECORD:

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STIPULATION TO EXTEND DISCOVERY CUT OFF

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COMES NOW, plaintiffs, FRISCO HONNEVK, BOUALAI VONGPHACHANH,

2 and defendant, FARMERS NEW WORLD LIFE INSURANCE COMPANY, and each of
3 them, by and between their respective attorneys of record, hereby stipulate to (1) continue the
4 September 28, 2012, expert designation deadline to November 2, 2012, (2) continue the
5 September 30, 2012, non-expert discovery cut off date to November 2, 2012, and (3)
6 continue the November 15, 2012 expert discovery cut off date to November 30, 2012.
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This Stipulation is entered into in good faith and not for the purpose of delay, as set

8 forth below.
9 1.
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FACTS SUPPORTING STIPULATION
This stipulation is premised upon an agreement by and between plaintiffs and

11 defendant to further explore settlement alternatives before concluding discovery. Given the
12 approaching September 30, 2012, non-expert discovery cut off date, and since trial is not until
13 March 13, 2013, the parties have agreed to discuss settlement options and alternatives and
14 seriously consider any reasonable settlement demand made by plaintiffs. One previous
15 request for an extension has been granted.
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STIPULATION

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Based on the foregoing, the parties hereby stipulate to (1) continue the existing expert

18 designation deadline to November 2, 2012; (2) continue the September 30, 2012, non-expert
19 discovery cut off to November 2, 2012; and (3) continue the November 15, 2012, expert
20 discovery cut off to November 30, 2012.
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IT IS SO STIPULATED.

23 DATED: September 28, 2012

MURCHISON & CUMMING, LLP

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By: /s/
William D. Naeve
Attorneys for Defendant,
FARMERS NEW WORLD LIFE
INSURANCE COMPANY

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STIPULATION TO EXTEND DISCOVERY CUT OFF

1 DATED: September 28, 2012

TIMOTHY I. MARKS & ASSOCIATES

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By: /s/
Timothy I. Marks
Attorneys for Plaintiffs
FRISCO HONNEVK and BOUALAI
VONGPHACHANH

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ORDER

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Based upon the foregoing and GOOD CAUSE APPEARING THEREFOR,

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IT IS SO ORDERED:

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Expert designation deadline in this litigation is continued from September 28, 2012, to
November 2, 2012. Non-expert discovery cut off is continued from September 30, 2012, to
November 2, 2012. Expert discovery cut off is continued from November 15, 2012, to
November 30, 2012.

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IT IS SO ORDERED.

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Dated:

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/s/ Dennis

October 9, 2012

UNITED STATES MAGISTRATE JUDGE
DEAC_Signature-END:

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L. Beck

3b142a

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STIPULATION TO EXTEND DISCOVERY CUT OFF