Opinion
No. 2:11-cv-03018-GEB-KJN
03-20-2013
Alexandra Nicholson, Plaintiff, v. Allstate Insurance Company, et al., Defendants.
MACKENROTH & LAIRD LLP Ralph E. Laird Attorneys for Plaintiff Alexandra Nicholson SNR DENTON US LLP Jeffry Butler Attorneys for Defendant Allstate Insurance Company
RALPH E. LAIRD (State Bar No. 166984)
Mackenroth & Laird, LLP
134 Almond Street
Auburn, CA 95603
Tel: (530) 889-1912
Fax: (530) 889-1962
Attorneys for Plaintiff
Alexandra Nicholson
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
Stipulation and [Proposed] Order
Continuing Dates Set in Scheduling Order
The Parties, by and through their respective counsel of record, hereby stipulate and agree as follows and respectfully request the Court to approve and give effect to their stipulation:
1. On October 9, 2012, Ronald C. Schwarzkopf, of Schwarzkopf Law, substituted in as counsel for Plaintiff Alexandra Nicholson in place of her former attorney, Jon S. Allin, formerly of Schwarzkopf & Allin. At that time, Mr. Allin was winding up his practice and commencing a position with the California Attorney General's Office.
2. On Friday, December 7, 2012, Ralph E. Laird, of Mackenroth & Laird, LLP, substituted in as counsel for Plaintiff Alexandra Nicholson in place of her former attorney, Ronald C. Schwarzkopf.
3. The parties have proceeded with additional written discovery and productions of documents and have completed the depositions of Plaintiff and an Allstate employee, Jess Molina. Two depositions are currently scheduled for March 22nd, and additional depositions are anticipated and would preferably be completed before the initial expert disclosure date which is currently March 29, 2013. One of the witnesses had a death in his family which caused continuance of his deposition, which remains to be scheduled. The parties have agreed to continue the dates for the initial expert witness disclosure and the rebuttal expert disclosure as set forth below. The parties believe continuance of these disclosure dates will not impact any of the other dates currently set in the scheduling order.
4. The existing scheduling order dates are as follows:
+-------------------------------------------------------+ ¦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 ¦ +--------------------------------------+----------------¦ ¦Final Pretrial Conference: ¦November 4, 2013¦ +--------------------------------------+----------------¦ ¦Trial to commence: ¦January 28, 2014¦ +-------------------------------------------------------+
NOW, THEREFORE, IT IS AGREED AND STIPULATED THAT good cause exists to continue to the dates for initial expert witnesses disclosure and rebuttal expert disclosure to the following dates:
+-----------------------------------------------------+ ¦Initial expert witnesses disclosed by:¦April 26, 2013¦ +--------------------------------------+--------------¦ ¦Rebuttal experts disclosed by: ¦May 24, 2013 ¦ +-----------------------------------------------------+
The date for completion of discovery, the last date for motions, the date for the Final Pretrial Conference, and the date to commence Trial shall remain the same as set forth herein above.
MACKENROTH & LAIRD LLP
By: ______________________
Ralph E. Laird
Attorneys for Plaintiff
Alexandra Nicholson
SNR DENTON US LLP
By: ______________________
Jeffry Butler
Attorneys for Defendant
Allstate Insurance Company
IT IS SO ORDERED.
______________________
GARLAND E. BURRELL, JR.
Senior United States District Judge