Reynolds v. Suntrust Mortgage, Inc.

Filing 13

STIPULATION and ORDER signed by Magistrate Judge Dale A. Drozd on 8/26/2011 ORDERING 12 the deposition of Kimberly Pannell-Reynolds aka Kimberly Pannell shall be taken on 9/14/2011. This deposition may take place beyond the 8/29/2011 discovery cut-off in this case. No other discovery deadline is altered by this order. (Reader, L)

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EDWARD R. BUELL, III (State Bar No. 240494)
[e-mail]
KURT C. WENDLENNER (State Bar No. 238434)
[e-mail]
SEVERSON & WERSON
A Professional Corporation
One Embarcadero Center, Suite 2600
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant
SUNTRUST MORTGAGE, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO DIVISION

11 JOEL S. REYNOLDS,

Case No.: 2:10-cv-01508-WBS-DAD

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STIPULATION AND ORDER RE
DEPOSITION OF KIMBERLY
PANNELL AKA KIMBERLY PANNELLREYNOLDS

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Plaintiff,
vs.

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DOES 1 through 50,
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Defendants.
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Complaint filed: April 19, 2010

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The parties hereto, by and through their respective attorneys of record, have entered into
this Stipulation based on the following facts:
WHEREAS third-party deponent Kimberly Pannell-Reynolds aka Kimberly Pannell is
believed to have material information pertinent to the subject litigation;
WHEREAS the parties were unable to agree to a deposition date for Kimberly PannellReynolds aka Kimberly Pannell on or before the discovery cut-off date;
WHEREAS deponent Kimberly Pannell-Reynolds has been contacted and has agreed to
attend her deposition on September 14, 2011.

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Based on the foregoing, it is hereby STIPULATED and AGREED as follows:

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The deposition of Kimberly Pannell-Reynolds aka Kimberly Pannell, will take place on

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September 14, 2011 at the Fairfield Inn Tracy, 2410 Naglee Road, Tracy, CA, 95376. This
11950/0063/958143.1

Stipulation and Order Re Depo of Kimberly Pannell
Case No.: 2:10-cv-01508-WBS DAD

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deposition will take place beyond the August 29, 2011 discovery cut-off in this case. This

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Stipulation and Agreement shall not impact any other discovery deadlines in this action.

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DATED: August 24, 2011
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SEVERSON & WERSON
A Professional Corporation

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By:

/s/ Kurt C. Wendlenner
Kurt C. Wendlenner

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Attorneys for Defendant
SUNTRUST MORTGAGE, INC.

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ROBINSON BRADFORD LLP

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By:
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/s/ Matthew Bradford
Matthew Bradford

Attorneys for Plaintiff
JOEL S. REYNOLDS

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ORDER
Pursuant to the parties’ stipulation, the deposition of Kimberly Pannell-Reynolds aka

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Kimberly Pannell shall be taken on September 14, 2011. This deposition may take place beyond

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the August 29, 2011 discovery cut-off in this case. No other discovery deadline is altered by this

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order.

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IT IS SO ORDERED.
Date: 8/26/2011
C_Signature-END:

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Ddad1\orders.civil\reynolds1508.stipord.pannell.dep3hep3

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-211950/0063/958143.1

Stipulation and Order Re Depo of Kimberly Pannell
Case No.: 2:10-cv-01508-WBS DAD