Nicholson v. Allstate Insurance Company

Filing 24

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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1 2 3 RALPH E. LAIRD (State Bar No. 166984) Mackenroth & Laird, LLP 134 Almond Street Auburn, CA 95603 Tel: (530) 889-1912 Fax: (530) 889-1962 4 5 Attorneys for Plaintiff Alexandra Nicholson 6 7 8 9 10 11 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 12 13 14 UNITED STATES DISTRICT COURT 15 EASTERN DISTRICT OF CALIFORNIA 16 17 18 19 20 21 Alexandra Nicholson, ) ) Plaintiff, ) ) v. ) ) Allstate Insurance Company, et al., ) ) Defendants. ) ________________________________________ ) No. 2:11-cv-03018-GEB-KJN Stipulation and [Proposed] Order Continuing Dates Set in Scheduling Order 22 23 24 25 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: 1. On October 9, 2012, Ronald C. Schwarzkopf, of Schwarzkopf Law, substituted in as 26 counsel for Plaintiff Alexandra Nicholson in place of her former attorney, Jon S. Allin, formerly of 27 Schwarzkopf & Allin. At that time, Mr. Allin was winding up his practice and commencing a 28 position with the California Attorney General’s Office. 1 Stipulation and [Proposed] Order Continuing Dates Set in Scheduling Order 1 2. On Friday, December 7, 2012, Ralph E. Laird, of Mackenroth & Laird, LLP, 2 substituted in as counsel for Plaintiff Alexandra Nicholson in place of her former attorney, Ronald 3 C. Schwarzkopf. 4 3. The parties have proceeded with additional written discovery and productions of 5 documents and have completed the depositions of Plaintiff and an Allstate employee, Jess Molina. 6 Two depositions are currently scheduled for March 22nd, and additional depositions are anticipated 7 and would preferably be completed before the initial expert disclosure date which is currently March 8 29, 2013. One of the witnesses had a death in his family which caused continuance of his deposition, 9 which remains to be scheduled. The parties have agreed to continue the dates for the initial expert 10 witness disclosure and the rebuttal expert disclosure as set forth below. The parties believe 11 continuance of these disclosure dates will not impact any of the other dates currently set in the 12 scheduling order. 13 4. The existing scheduling order dates are as follows: 14 Initial expert witnesses disclosed by: March 29, 2013 15 Rebuttal experts disclosed by: April 26, 2013 16 All discovery completed by: June 29, 2013 17 Last hearing date for motions: August 26, 2013 18 Final Pretrial Conference: November 4, 2013 19 Trial to commence: January 28, 2014 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28 /// 2 Stipulation and [Proposed] Order Continuing Dates Set in Scheduling Order 1 NOW, THEREFORE, IT IS AGREED AND STIPULATED THAT good cause exists to 2 continue to the dates for initial expert witnesses disclosure and rebuttal expert disclosure to the 3 following dates: 4 Initial expert witnesses disclosed by: April 26, 2013 5 Rebuttal experts disclosed by: May 24, 2013 6 The date for completion of discovery, the last date for motions, the date for the Final Pretrial 7 Conference, and the date to commence Trial shall remain the same as set forth herein above. 8 Dated: March 18, 2012 MACKENROTH & LAIRD LLP 9 10 By: 11 /s/ Ralph E. Laird Ralph E. Laird Attorneys for Plaintiff Alexandra Nicholson 12 13 Dated: March 18, 2012 SNR DENTON US LLP 14 By: /s/ Jeffry Butler (as authorized on 3/18/12) Jeffry Butler Attorneys for Defendant Allstate Insurance Company 15 16 17 18 19 20 IT IS SO ORDERED. Dated: March 20, 2013 21 22 23 GARLAND E. BURRELL, JR. Senior United States District Judge 24 25 26 27 28 3 Stipulation and [Proposed] Order Continuing Dates Set in Scheduling Order

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