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James Michael Flohr and Wendy v. Fidelity and Guaranty Group Insurance Trust Dba Old Mutual

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA SACRAMENTO DIVISION


December 9, 2010

JAMES MICHAEL FLOHR AND WENDY
FLOHR,
PLAINTIFFS,
v.
FIDELITY AND GUARANTY GROUP INSURANCE TRUST DBA OLD MUTUAL FINANCIAL LIFE INSURANCE COMPANY AND DOES 1 THROUGH 50, INCLUSIVE, DEFENDANTS.

Compl. Filed: September 17, 2009

STIPULATION AND ORDER TO EXTEND DISCOVERY CUT-OFF DATES

COMES NOW Plaintiff JAMES MICHAEL FLOHR, and Defendant OM FINANCIAL LIFE INSURANCE COMPANY erroneously sued as FIDELITY AND GUARANTY GROUP INSURANCE TRUST dba OLD MUTUAL FINANCIAL LIFE INSURANCE COMPANY and hereby stipulate to extend certain discovery cut-off dates.

Both Plaintiff and Defendants are in agreement regarding an extension of time because due to recent trial calendars, the current discovery schedule does not allow enough time to complete all of the necessary discovery by the deadlines set forth. All parties are in agreement to an extension of the currently scheduled deadlines as set forth below.

This matter is currently set for trial on August 16, 2011. The parties therefore stipulate and agree as follows:

1. To extend the fact discovery cutoff to February 4, 2011;

2. To extend the Designation of Expert Witnesses deadline until February 18, 2011. SO STIPULATED.

DATED: December 9, 2010. REED SMITH LLP By Henry C. Wang Henry C. Wang Brett B. Goodman Attorneys for Defendant OM Financial Life Insurance Company erroneously sued as Fidelity and Guaranty Group Insurance Trust dba Old Mutual Financial Life Insurance Company

DATED: December 9, 2010. HINTZ & WELCH By Joseph A. Welch Joseph A. Welch Attorney for Plaintiffs James Michael Flohr

ORDER PURSUANT TO THE ABOVE STIPULATION, IT IS SO ORDERED.

20101209

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