Nicholson v. Allstate Insurance Company - Document 22

Court Description:

STIPULATION AND ORDER signed by Judge Garland E. Burrell, Jr on 12/13/12 ORDERING: Initial expert witnesses disclosed by: March 29, 2013; Rebuttal experts disclosed by: April 26, 2013; All discovery completed by: June 29, 2013; Last hearing date for motions: August 26, 2013 at 9:00 a.m.; Final Pretrial Conference: November 4, 2013 at 11:00 a.m; A joint pretrial statement shall be filed seven days prior to the hearing; Trial to commence: January 28, 2014 at 9:00 a.m. (Becknal, R)

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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 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. On Monday, December 10th and Tuesday, December 11th of 2012, counsel for the 5 parties discussed the dates and deadlines of the scheduling order at length in an effort to agree on 6 new proposed dates and deadlines in order to allow additional time for disclosure of experts, for 7 completion of discovery, and to file motions. In particular, counsel for the parties discussed 8 additional discovery to take place before experts are disclosed, having the discovery completion 9 deadline approximately two months before the deadline to hear motions, and having the Final 10 11 Pretrial Conference take place at least two months after the deadline to hear motions. 4. The existing scheduling order dates are as follows: 12 Initial expert witnesses disclosed by: December 31, 2012 13 Rebuttal experts disclosed by: January 31, 2013 14 All discovery completed by: April 1, 2013 15 Last hearing date for motions: June 3, 2013 16 Final Pretrial Conference: August 12, 2013 17 Trial to commence: October 22, 2013 18 19 NOW, THEREFORE, IT IS AGREED AND STIPULATED THAT good cause exists to continue the above events to the following dates: 20 Initial expert witnesses disclosed by: March 29, 2013 21 Rebuttal experts disclosed by: April 26, 2013 22 All discovery completed by: June 29, 2013 23 Last hearing date for motions: August 29, 2013 24 Final Pretrial Conference: November 11, 2013 25 Trial to commence: January 20, 2014 26 27 28 2 Stipulation and [Proposed] Order Continuing Dates Set in Scheduling Order 1 Dated: December 13, 2012 MACKENROTH & LAIRD LLP 2 3 By: 4 /s/ Ralph E. Laird Ralph E. Laird Attorneys for Plaintiff Alexandra Nicholson 5 6 Dated: December 13, 2012 SNR DENTON US LLP 7 By: /s/ Jeffry Butler (as authorized on 12/13/12) Jeffry Butler Attorneys for Defendant Allstate Insurance Company 8 9 10 11 12 14 IT IS SO ORDERED except since two of the proposed dates are court holidays and one is not an available hearing date for law and motion, the last hearing date for motions is rescheduled for August 26, 2013, at 9:00 a.m. and the pretrial conference is rescheduled for November 4, 2013, at 11:00 a.m. A joint pretrial statement shall be filed seven days prior to the hearing. The trial is rescheduled for January 28, 2014, at 9:00 a.m. 15 Dated: December 13, 2012 13 16 17 18 GARLAND E. BURRELL, JR. Senior United States District Judge 19 20 21 22 23 24 25 26 27 28 3 Stipulation and [Proposed] Order Continuing Dates Set in Scheduling Order