Nicholson v. Allstate Insurance Company
Filing
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STIPULATION and ORDER 23 continuing dates signed by Judge Garland E. Burrell, Jr. on 3/20/2013. Initial Expert Witnesses shall be disclosed by 4/26/2013. Rebuttal Experts shall be disclosed by 5/24/2013. The dates for completion of Discovery, for Motions, Final Pretrial Conference, and Trial shall remain the same as set forth. (Marciel, M)
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RALPH E. LAIRD (State Bar No. 166984)
Mackenroth & Laird, LLP
134 Almond Street
Auburn, CA 95603
Tel: (530) 889-1912
Fax: (530) 889-1962
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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: (415) 882-5000
Facsimile: (415) 882-0300
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 to 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.
The parties have proceeded with additional written discovery and productions of
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documents and have completed the depositions of Plaintiff and an Allstate employee, Jess Molina.
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Two depositions are currently scheduled for March 22nd, and additional depositions are anticipated
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and would preferably be completed before the initial expert disclosure date which is currently March
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29, 2013. One of the witnesses had a death in his family which caused continuance of his deposition,
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which remains to be scheduled. The parties have agreed to continue the dates for the initial expert
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witness disclosure and the rebuttal expert disclosure as set forth below. The parties believe
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continuance of these disclosure dates will not impact any of the other dates currently set in the
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scheduling order.
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4.
The existing scheduling order dates are as follows:
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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 26, 2013
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Final Pretrial Conference:
November 4, 2013
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Trial to commence:
January 28, 2014
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Stipulation and [Proposed] Order Continuing Dates Set in Scheduling Order
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NOW, THEREFORE, IT IS AGREED AND STIPULATED THAT good cause exists to
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continue to the dates for initial expert witnesses disclosure and rebuttal expert disclosure to the
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following dates:
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Initial expert witnesses disclosed by:
April 26, 2013
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Rebuttal experts disclosed by:
May 24, 2013
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The date for completion of discovery, the last date for motions, the date for the Final Pretrial
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Conference, and the date to commence Trial shall remain the same as set forth herein above.
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Dated: March 18, 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: March 18, 2012
SNR DENTON US LLP
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By: /s/ Jeffry Butler (as authorized on 3/18/12)
Jeffry Butler
Attorneys for Defendant
Allstate Insurance Company
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IT IS SO ORDERED.
Dated: March 20, 2013
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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
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