Raines v. Standard Insurance Company

Filing 20

STIPULATION AND ORDER extending deadlines; Expert disclosures by 12/21/2010; Final hearing re dispositive motions not later than 3/1/2011; Signed by Judge Marilyn Hall Patel on 11/30/2010. (awb, COURT STAFF) (Filed on 12/1/2010)

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SHAWN HANSON (SBN 109321) MARIA ELLINIKOS (SBN 235528) EZEKIEL L. RAUSCHER (SBN 269141) AKIN GUMP STRAUSS HAUER & FELD LLP 580 California Street, Suite 1500 San Francisco, CA 94104 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant STANDARD INSURANCE COMPANY UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

HELEN RAINES, Plaintiff, v. STANDARD INSURANCE COMPANY, Defendant.

Case No. 3:10-CV-00093-MHP STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES SET FORTH IN THE JOINT CASE MANAGEMENT STATEMENT AND ORDER Judge: Hon. Marilyn H. Patel

STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES SET FORTH IN THE JOINT CASE MANAGEMENT STATEMENT AND ORDER 3:10-CV-00093-MHP

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WHEREAS the parties' deadline to disclose identities of all witnesses to be called in each party's case-in-chief is December 1, 2010; WHEREAS the parties' deadline to disclose identities, resumes, final reports and all other matters required by Federal Rule of Civil Procedure 26(a)(2) is December 1, 2010; WHEREAS the deadline to hear motions directed to the merits of all or part of the case is February 17, 2011; WHEREAS the parties are engaged in settlement discussions and believe that further discussions would be productive and desirable; WHEREAS the parties would like to dedicate their resources towards continuing their settlement discussions and for that reason would like to minimize their litigation activity during the period of these discussions; WHEREAS the parties, in furtherance of the objective of minimizing their litigation activity during the period of their settlement discussions, desire to extend the deadline to disclose identities of all witnesses to be called in each party's case-in-chief and to disclose identities, resumes, final reports and all other matters required by Federal Rule of Civil Procedure 26(a)(2) from December 1, 2010 to December 21, 2010, and to extend the deadline to hear motions directed to the merits of all or part of the case from February 17, 2011 to March 1, 2011. WHEREAS the parties respectfully request that the Court extend the December 1, 2010 deadlines to December 21, 2010 and the February 17, 2011 deadline to March 1, 2011. // // // // // // // // // 1
STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES SET FORTH IN THE JOINT CASE MANAGEMENT STATEMENT AND ORDER 3:10-CV-00093-MHP

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NOW THEREFORE, the parties, by and through their counsel of record, hereby stipulate and agree, subject to the court's approval, that the deadlines to disclose identities of all witnesses to be called in each party's case-in-chief and to disclose identities, resumes, final reports and all other matters required by Federal Rule of Civil Procedure 26(a)(2) shall be December 21, 2010, and the deadline to hear motions directed to the merits of all or part of the case shall be March 1, 2011. IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. DATED: November 29, 2010 AKIN GUMP STRAUSS HAUER & FELD LLP By /s/ Maria Ellinikos MARIA ELLINIKOS Attorneys for Defendant STANDARD INSURANCE COMPANY In accordance with General Order No. 45, Rule X, the above signatory attests that concurrence in the filing of this document has been obtained from the signatory below. DATED: November 29, 2010, 2010 LAW OFFICES OF LAURENCE F. PADWAY By /s/ Laurence F. Padway LAURENCE FRED PADWAY Attorneys for Plaintiff HELEN RAINES

PURSUANT TO STIPULATION, IT IS SO ORDERED. 30 DATED: November ____, 2010

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