Cason v. Federated Life Insurance Company

Filing 96

STIPULATION AND ORDER EXTENDING DISCOVERY DEADLINES re 92 Stipulation filed by Federated Life Insurance Company. Signed by Judge Edward M. Chen on 6/13/11. (bpf, COURT STAFF) (Filed on 6/13/2011)

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THE COSTA LAW FIRM
DANIEL P. COSTA, State Bar No. 110919
2489 Sunrise Blvd., Suite A
Gold River, California 95670
Telephone: [phone]
Telecopier: [phone]

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Attorneys for Defendant
FEDERATED LIFE INSURANCE COMPANY

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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CHERYL CASON,

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Plaintiff,
vs.

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FEDERATED LIFE INSURANCE
COMPANY; a Minnesota Corporation
registered to do business in California; and
DOES 1 to 100,

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Defendants.
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CASE NO: C 10-00792 EMC
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE
DISCOVERY CUT-OFF DATES

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IT IS HEREBY AGREED AND STIPULATED to by the parties through their respective

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counsel of record that the discovery cut-off dates in this matter be briefly continued. Specifically, the

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parties agreed and stipulated that non-expert discovery in this matter, presently scheduled to close June

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20, 2011, be continued to July 7, 2011, and expert discovery, presently scheduled to close June 20,

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2011, be continued to August 4, 2011. Expert disclosures will now be due July 7, 2011, and rebuttal

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experts shall be disclosed and reports provided by July 21, 2011.

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This short continuance of the discovery deadline is necessary because lead counsel for

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Defendant FEDERATED LIFE INSURANCE COMPANY (“FEDERATED”), Dan Costa, is in trial
STIPULATION AND [PROPOSED] ORDER TO TO CONTINUE DISCOVERY CUT-OFF DATES

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in another matter and will have very limited availability through approximately June 17, 2011, or later.

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Both parties, having met and conferred regarding new discovery deadlines and having secured

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deponents’ availability for new dates agreeable to both parties, agree that good cause exists for this

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short continuance of applicable discovery deadlines.

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STIPULATED AND AGREED TO BY:

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DATED: June 8, 2011

THE COSTA LAW FIRM

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By:

/s/ DANIEL P. COSTA
DANIEL P. COSTA, ESQ.
Attorneys for Defendant
FEDERATED INSURANCE COMPANY

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DATED: June 8, 2011

DL LAW GROUP

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By:

/s/ DAVID LILIENSTEIN
DAVID LILIENSTEIN, ESQ.
ALICE WOLFSON, ESQ.
Attorneys for Plaintiff
CHERYL CASON

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[PROPOSED] ORDER

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IT IS HEREBY ORDERED that the discovery cut-off dates in the matter of CASON v.

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FEDERATED LIFE INSURANCE COMPANY (CASE NO: C 10-00792 EMC) be continued briefly.

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Non-expert discovery is continued from June 20, 2011, to July 7, 2011, and expert discovery is

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continued from June 20, 2011, to August 4, 2011. Expert disclosures will now be due July 7, 2011,

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and rebuttal experts shall be disclosed and reports provided by July 21, 2011.

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dward M
Judge E

EDWARD M. CHEN

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MAGISTRATE JUDGE
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Chen

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STIPULATION AND [PROPOSED] ORDER TO TO CONTINUE DISCOVERY CUT-OFF DATES

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Dated: June ____, 2011

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