Garcia v. Standard Life Insurance Company

Filing 24

STIPULATION AND ORDER signed by Senior Judge William B. Shubb on 2/24/2015 ALLOWING the manual submission of two DVDs containing the Depositions of Kathleen Garcia taken on 9/29/2014, 12/23/2014, 12/26/2014 and 1/9/2015. (Michel, G.)

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WARREN H. NELSON, JR., # 104744
A PROFESSIONAL CORPORATION
6161 El Cajon Blvd., # 273
San Diego, CA 92115
Telephone: [phone]
Facsimile: 619 501 7948
Email: [e-mail]
Attorney for Defendant
Standard Insurance Company

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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KATHLEEN GARCIA,
Plaintiff,

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vs.

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STANDARD INSURANCE
COMPANY, et al.

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Defendants.

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Case No.: 2:13-cv-02164-WBS-CKD
STIPULATION AND [PROPOSED]
ORDER TO ALLOW MANUAL
SUBMISSION OF MATTER ON DVD
No hearing set or required.
Before the Honorable William B.
Shubb, Judge

Plaintiff Kathleen Garcia and Defendant Standard Insurance Company
(“Standard”) stipulate that Standard may manually submit to the Court:
1. On a single DVD, the videotape of the Deposition of Kathleen Garcia taken
on September 29, 2014, as prepared by Barkley Reporters.

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2. On a single DVD, surveillance videotape of Kathleen Garcia taken on

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December 23, 26, 2014, and January 9, 2015. Garcia stipulates to this

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based on the representations of Standard’s counsel that the DVD is an exact,

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true and correct copy of the video surveillance produced by Standard’s

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counsel on a thumb drive to Garcia’s counsel on or about January 13, 2015.

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STIP/PROP ORDER TO ALLOW MANUAL SUBMISSION OF TWO DVDs – 2:13-cv-02164-WBS-CKD - 1

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3. By stipulating to manual submission of the foregoing two DVDs, Garcia

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does not admit that the materials are authentic, admissible for any purpose

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or waive any objection to the Court’s consideration of these materials for

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any purpose asserted by Standard or otherwise. Garcia does nothing more

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than agree that the two DVDs may be submitted manually.

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IT IS SO STIPULATED.

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Dated: February 19, 2015
/s/ Warren H. Nelson, Jr.
WARREN H. NELSON, JR.
A PROFESSIONAL CORPORATION
6161 El Cajon Boulevard, # 273
San Diego, CA 92115

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Attorney for Defendant
STANDARD INSURANCE COMPANY

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IT IS SO STIPULATED.
Dated: February 19, 2015

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/s/ Dan Rainsbury
Dan Rainsbury

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DAVID ALLEN & ASSOCIATES
5230 Folsom Boulevard
Sacramento, CA 95819

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Attorneys for Plaintiff
KATHLEEN GARCIA

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IT IS SO ORDERED.

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Dated: February 24, 2015

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STIP/PROP ORDER TO ALLOW MANUAL SUBMISSION OF TWO DVDs – 2:13-cv-02164-WBS-CKD - 2