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TED GAYLORD and SHERI GAYLORD, as individuals and dba J&T v. NATIONWIDE MUTUAL INSURANCE COMPANY

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA FRESNO DIVISION


November 30, 2010

TED GAYLORD AND SHERI GAYLORD, AS INDIVIDUALS AND DBA J&T CATTLE COMPANY, PLAINTIFFS
v.
NATIONWIDE MUTUAL INSURANCE COMPANY, AN OHIO CORPORATION, AMCO INSURANCE COMPANY, AN IOWA CORPORATION; ALLIED GROUP, INC, AN IOWA CORPORATION; AND DOES 1 THROUGH 100, DEFENDANTS.

The opinion of the court was delivered by: Michael J. Seng United States Magistrate Judge

STIPULATION TO EXTEND DISCOVERY DEADLINES AND ORDER

Plaintiffs Ted and Sheri Gaylord and defendants Nationwide Mutual Insurance Company and AMCO Insurance Company, through their attorneys of record, hereby submit this stipulated 2 request for an Order continuing discovery deadlines in the above-referenced matter as follows:

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Non Expert Discovery: From 11/26/10 to 03/11/11

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Expert Disclosure: From 12/01/10 to 03/18/11

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Supplemental Expert From 12/17/10 to 04/01/11

Disclosure

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Non-Dispositive Pre-Trial From 01/24/11 to 04/08/11 Motions filed by 9 Non- Dispositive Pre-Trial From 02/25/11 to 05/09/11 Motion Hearing Date

Expert Discovery Cut- From 01/20/11 to 05/11/11 Off

Dispositive Motion Deadline Remains 03/11/11

In support of this stipulated request, I Lisa Silva Passalacqua, do hereby declare:

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1. I am an attorney at law, licensed to practice in all courts in the State of California and an attorney with the law firm of Wilson, Elser, Moskowitz, Edelman & Dicker LLP, counsel of record for Nationwide Mutual Life Insurance Company and AMCO Insurance Company. I have personal knowledge of the facts stated herein, and am competent to testify to the same. The matters set forth herein are true and correct to the best of my knowledge and belief as follows:

2. Plaintiffs' counsel George Rodarakis and I have discussed the Scheduling Order presently in place in this case. In an effort to minimize the attorney's fees and costs to our clients and judicial efficiency, we have agreed to continue the discovery deadlines as set forth above in order to have a summary judgment motion heard prior to concluding discovery. This will enable the parties to possibly eliminate or reduce attorney's fees incurred in conducting extensive discovery depending on the Court's ruling on the summary judgment motion. Other than the discovery related deadlines set forth above, no other Court ordered dates, including the dispositive motion date, 1 pre-trial dates or the trial date, will be impacted by this Stipulation. 2

Dated: November 24, 2010

WILSON, ELSER, MOSKOWITZ, EDELMAN & 3 DICKER LLP

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By:

/s/

Lisa S. Passalacqua Attorneys for Defendant Nationwide Mutual Life Insurance Company 9 and AMCO Insurance Company SO STIPULATED

Dated: November 24, 2010 DAMRELL NELSON SCHRIMP PALLIOS PACHER & SILVA

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By:

/s/

George P. Rodarakis Attorneys for Plaintiffs Ted and Sheri Gaylord

ORDER

IT IS SO ORDERED.

/s/

DEAC_Signature-END:

ci4d6

20101130

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