Nicholson v. Allstate Insurance Company

Filing 22

STIPULATION AND ORDER signed by Judge Garland E. Burrell, Jr on 12/13/12 ORDERING: Initial expert witnesses disclosed by: March 29, 2013; Rebuttal experts disclosed by: April 26, 2013; All discovery completed by: June 29, 2013; Last hearing date for motions: August 26, 2013 at 9:00 a.m.; Final Pretrial Conference: November 4, 2013 at 11:00 a.m; A joint pretrial statement shall be filed seven days prior to the hearing; Trial to commence: January 28, 2014 at 9:00 a.m. (Becknal, R)

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RALPH E. LAIRD (State Bar No. 166984)
Mackenroth & Laird, LLP
134 Almond Street
Auburn, CA 95603
Tel: [phone]
Fax: [phone]

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Attorneys for Plaintiff
Alexandra Nicholson

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CYNTHIA L. MELLEMA (State Bar No. 122798)
JEFFRY BUTLER (State Bar No. 180936)
MEGAN BARKER (State Bar No. 245991)
SNR Denton US LLP
525 Market Street, 26th Floor
San Francisco, CA 94102-2734
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
Allstate Insurance Company

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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Alexandra Nicholson,

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Plaintiff,
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v.
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Allstate Insurance Company, et al.,
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Defendants.
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________________________________________ )

No. 2:11-cv-03018-GEB-KJN
Stipulation and [Proposed] Order
Continuing Dates Set in Scheduling
Order

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The Parties, by and through their respective counsel of record, hereby stipulate and agree as
follows and respectfully request the Court approve and give effect to their stipulation:
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On October 9, 2012, Ronald C. Schwarzkopf, of Schwarzkopf Law, substituted in as

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counsel for Plaintiff Alexandra Nicholson in place of her former attorney, Jon S. Allin, formerly of

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Schwarzkopf & Allin. At that time, Mr. Allin was winding up his practice and commencing a

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position with the California Attorney General’s Office.
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Stipulation and [Proposed] Order Continuing Dates Set in Scheduling Order

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2.

On Friday, December 7, 2012, Ralph E. Laird, of Mackenroth & Laird, LLP,

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substituted in as counsel for Plaintiff Alexandra Nicholson in place of her former attorney, Ronald

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C. Schwarzkopf.

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3.

On Monday, December 10th and Tuesday, December 11th of 2012, counsel for the

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parties discussed the dates and deadlines of the scheduling order at length in an effort to agree on

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new proposed dates and deadlines in order to allow additional time for disclosure of experts, for

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completion of discovery, and to file motions. In particular, counsel for the parties discussed

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additional discovery to take place before experts are disclosed, having the discovery completion

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deadline approximately two months before the deadline to hear motions, and having the Final

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Pretrial Conference take place at least two months after the deadline to hear motions.
4.

The existing scheduling order dates are as follows:

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Initial expert witnesses disclosed by:

December 31, 2012

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Rebuttal experts disclosed by:

January 31, 2013

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All discovery completed by:

April 1, 2013

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Last hearing date for motions:

June 3, 2013

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Final Pretrial Conference:

August 12, 2013

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Trial to commence:

October 22, 2013

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NOW, THEREFORE, IT IS AGREED AND STIPULATED THAT good cause exists to
continue the above events to the following dates:

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Initial expert witnesses disclosed by:

March 29, 2013

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Rebuttal experts disclosed by:

April 26, 2013

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All discovery completed by:

June 29, 2013

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Last hearing date for motions:

August 29, 2013

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Final Pretrial Conference:

November 11, 2013

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Trial to commence:

January 20, 2014

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Stipulation and [Proposed] Order Continuing Dates Set in Scheduling Order

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Dated: December 13, 2012

MACKENROTH & LAIRD LLP

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By:

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/s/ Ralph E. Laird
Ralph E. Laird
Attorneys for Plaintiff
Alexandra Nicholson

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Dated: December 13, 2012

SNR DENTON US LLP

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By: /s/ Jeffry Butler (as authorized on 12/13/12)
Jeffry Butler
Attorneys for Defendant
Allstate Insurance Company

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IT IS SO ORDERED except since two of the proposed dates are court holidays and one is
not an available hearing date for law and motion, the last hearing date for motions is rescheduled for
August 26, 2013, at 9:00 a.m. and the pretrial conference is rescheduled for November 4, 2013, at
11:00 a.m. A joint pretrial statement shall be filed seven days prior to the hearing. The trial is
rescheduled for January 28, 2014, at 9:00 a.m.

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Dated: December 13, 2012

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GARLAND E. BURRELL, JR.
Senior United States District Judge

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Stipulation and [Proposed] Order Continuing Dates Set in Scheduling Order