Miletak et al v. Allstate Insurance Company

Filing 311

STIPULATION AND ORDER re 309 Stipulation, filed by Allstate Indemnity Company, Vlaho Miletak, Allstate Insurance Company. Signed by Judge James Ware on 8/2/11. (sis, COURT STAFF) (Filed on 8/2/2011)

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GAYLE ATHANACIO, Esq., Bar No. 130068
SANFORD KINGSLEY, Esq. Bar No. 99849
SNR DENTON US LLP
525 Market Street, 26th Floor
San Francisco, CA 94105-2708

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Judge Ja

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Attorneys for Plaintiff

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es Ware

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Mark P. Millen, Esq., Bar No. 196718
MARK P. MILLEN, ATTORNEY AT LAW
2 North Santa Cruz Avenue, Suite 205
Los Gatos, California 95030
Telephone:
[phone]
Facsimile:
[phone]

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ERED

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IT IS S

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S DISTRICT
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SAMUEL KORNHAUSER, Esq., Bar No. 083528
LAW OFFICES OF SAMUEL KORNHAUSER
155 Jackson Street, Suite 1807
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]

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ED

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Attorneys for Defendants

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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VLAHO MILETAK, an individual on his own )
behalf and on behalf of all other automobile
)
insureds of Allstate Insurance Company,
)
)
Plaintiff,
)
)
v.
)
)
ALLSTATE INSURANCE COMPANY, an
)
Illinois corporation, ALLSTATE INDEMNITY )
COMPANY, an Illinois corporation and THE )
ALLSTATE CORPORATION, an Illinois
)
corporation,
)
)
Defendants.
)

Case No. C 06-03778 JW
STIPULATION AND [PROPOSED]
ORDER EXTENDING EXPERT
DISCOVERY CUT OFF FROM
JULY 29, 2011 TO OCTOBER 15,
2011 FOR PURPOSES OF TAKING
EXPERT DEPOSITIONS

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Stip.And [Proposed] Order Extending Discovery Cutoff For Purposes Of Taking Expert Depositions

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Plaintiff Vlaho Miletak and Defendants Allstate Insurance Company and Allstate

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Indemnity Company (collectively “Defendants”) hereby submit the following “Stipulation

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And [Proposed] Order Extending Expert Discovery Cut Off From July 29, 2011 To

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October 15, 2011 For Purposes Of Taking Expert Depositions”

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Pursuant to this Court’s May 20, 2011 Order (Docket # 286), the Court established a

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discovery cutoff for all discovery, including expert discovery, of July 29, 2011. Due to

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scheduling conflicts of counsel and of the expert witnesses (and an upcoming trial and

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vacations), the parties’ have been unable to complete the taking of depositions of the

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disclosed expert witnesses.

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The parties, without waiving their claims regarding allegedly past due discovery,

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respectfully request that the Court continue the existing Discovery Cutoff, solely for the

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purposes of taking expert witness depositions, to October 15, 2011 and hereby stipulate to

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the issuance of the attached Order.

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Dated: July 29, 2011

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LAW OFFICES OF SAMUEL KORNHAUSER,
AND LAW OFFICES OF MARK P. MILLEN

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By

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Attorneys for Plaintiff
VLAHO MILETAK

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Dated: July 29, 2011

/S/Samuel Kornhauser
SAMUEL KORNHAUSER

SNR DENTON US LLP

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By

/S/Sanford Kingsley
SANFORD KINGSLEY

Attorneys for Defendants
ALLSTATE INSURANCE COMPANY and
ALLSTATE INDEMNITY COMPANY

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STIPULATION AND [PROPOSED] ORDER EXTENDING EXPERT DISCOVERY
CUT OFF FROM JULY 29, 2011 TO OCTOBER 15, 2011 FOR PURPOSES OF
TAKING EXPERT DEPOSITIONS

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SAMUEL KORNHAUSER, Esq., Bar No. 083528
LAW OFFICES OF SAMUEL KORNHAUSER
155 Jackson Street, Suite 1807
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]

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Mark P. Millen, Esq., Bar No. 196718
MARK P. MILLEN, ATTORNEY AT LAW
2 North Santa Cruz Avenue, Suite 205
Los Gatos, California 95030
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiff

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GAYLE ATHANACIO, Esq., Bar No. 130068
SANFORD KINGSLEY, Esq. Bar No. 99849
SNR DENTON US LLP
525 Market Street, 26th Floor
San Francisco, CA 94105-2708

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Attorneys for Defendants

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IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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VLAHO MILETAK, an individual on his own )
behalf and on behalf of all other automobile
)
insureds of Allstate Insurance Company,
)
)
Plaintiff,
)
)
v.
)
)
ALLSTATE INSURANCE COMPANY, an
)
Illinois corporation, ALLSTATE INDEMNITY )
COMPANY, an Illinois corporation and THE )
ALLSTATE CORPORATION, an Illinois
)
corporation,
)
)
Defendants.
)

Case No. C 06-03778 JW
[PROPOSED] ORDER EXTENDING
DISCOVERY CUTOFF FROM JULY
29, 2011 TO OCTOBER 15, 2011 FOR
PURPOSES OF TAKING EXPERT
DEPOSITIONS

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The Court, having considered the parties’ “Stipulation And [Proposed] Order Extending Expert
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STIPULATION AND [PROPOSED] ORDER EXTENDING EXPERT DISCOVERY
CUT OFF FROM JULY 29, 2011 TO OCTOBER 15, 2011 FOR PURPOSES OF
TAKING EXPERT DEPOSITIONS

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Discovery Cut Off From July 29, 2011 To October 15, 2011 For Purposes Of Taking Expert

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Depositions and finding good cause, ORDERS AS FOLLOWS:

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1. The Discovery Cutoff solely for the purposes of taking expert witness depositions, is
extended to October 15, 2011.

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______________________________________

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HON. JAMES WARE

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UNITED STATES DISTRICT COURT JUDGE

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STIPULATION AND [PROPOSED] ORDER EXTENDING EXPERT DISCOVERY
CUT OFF FROM JULY 29, 2011 TO OCTOBER 15, 2011 FOR PURPOSES OF
TAKING EXPERT DEPOSITIONS