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Sarah Perez; Michelle Lackney v. State Farm Mut. Auto. Ins. Co.

June 16, 2011

SARAH PEREZ; MICHELLE LACKNEY;
RACHEL STEWART; RACHEL HARDYCK, ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
v.
STATE FARM MUT. AUTO. INS. CO., AN ILLINOIS CORPORATION; ALLSTATE INS. CO., AN ILLINOIS CORPORATION; GEICO, A MARYLAND 24 CORPORATION; CERTIFIED AUTO. PARTS ASS'N, DOING BUSINESS IN WASHINGTON,
D.C.; LIBERTY MUT. INS. CO., A MASSACHUSETTS CORPORATION; AND UN NAMED INSURANCE CONSPIRATORS,
DEFENDANTS.



The opinion of the court was delivered by: Hon. James Ware United States District Chief Judge

JAMES McMANIS (State Bar No. 40958) D U E R MICHAEL REEDY (State Bar No. 161002) T T MCMANIS FAULKNER N IS SO ORDERED 50 W. San Fernando St., Tenth Floor U A 3 San Jose, California 95113 I Telephone: (408) 279-8700 N Ware R O Judge James O E-mail: jmcmanis@mcmanislaw.com Facsimile: (408) 279-3244 N mreedy@mcmanislaw.com T L Attorneys for Plaintiffs RN F [Additional Counsel for Plaintiffs Appear on Signature Page] DIST ICT O RICHARD L. FENTON (admitted pro hac vice) 8 STEVEN H. FRANKEL (SBN 171919) BONNIE LAU (SBN 246188) 9 SNR DENTON US LLP 525 Market Street, 26th Floor 10 San Francisco, California 94105 Telephone: (415) 882-5000 11 Facsimile: (415) 882-0300 E-mail: richard.fenton@snrdenton.com steven.frankel@snrdenton.com bonnie.lau@snrdenton.com 13 Attorneys for Defendant Allstate Indemnity Company 14 [Additional Counsel for Other Defendants Appear on Signature Page]

STIPULATION AND [PROPOSED] ORDER REGARDING CLASS DISCOVERY SCHEDULE AND DEADLINES

Hardyck (collectively "Plaintiffs") and Defendants State Farm Mutual Automobile Insurance Automotive Parts Association, and Liberty Mutual Fire Insurance Company (collectively STIPULATION

Pursuant to the Court's June 3, 2011 Order Denying Motion for Administrative Relief

(Docket Entry No. 351), Plaintiffs Sarah Perez, Michelle Lackney, Rachel Stewart and Rachel Company, Allstate Indemnity Company, GEICO General Insurance Company, Certified 6

"Defendants"), by and through their respective undersigned counsel, have met and conferred to 8 work out a suitable discovery plan to complete class discovery, stipulate and agree as set forth 9 below, and respectfully request that the Court approve and give effect to their stipulation:

11 no later than July 6, 2011, including CD's with digitized images of all documents reviewed.

13 later July 18, 2011, including CD's with digitized images of all documents reviewed.

3. For experts retained by Plaintiffs, the CD's referenced in paragraphs 1 and 2 above

15 shall be personally served on the San Francisco office of SNR Denton US LLP for all 16

Kellogg, Huber, Hansen, Todd, Evans & Figel, P.L.L.C. for all Plaintiffs. 18

1. The parties shall personally serve supplemental reports for all affirmative experts

2. The parties shall personally serve supplemental reports for all rebuttal experts no

Defendants, and for experts retained by Defendants, the CD's shall be ...


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