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

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA


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 personally served on

4. Depositions of class experts shall take place between July 18, 2011 and July 26, 2011 according to the following schedule: 20

currently closes on July 13, 2011. A 13-day extension of the class discovery deadline to July 26, 2011 is necessary to complete class discovery and will not affect the September 12, 2011 27 hearing date on Plaintiffs' anticipated motion for class certification. Other than the modification 28

Case No. C06-01962 (JW) (PSG)

STIPULATION AND [PROPOSED] ORDER

Plaintiffs' Class Expert Noll: Thursday, July 21, 2011 at 9 am

Defendants' Class Expert Rubinfeld: Friday, July 22, 2011 at 9 am

Defendants' Class Expert Vogler: Monday, July 25, 2011 at 9 am

Defendants' Class Expert Cripe: Tuesday, July 26, 2011 at 9 am

5. Under the Court's April 13, 2011 Order (Docket Item No. 298), class discovery of the class discovery schedule set forth in Court's April 13, 2011 Order, no other extensions or 2 modifications have been obtained.

6. Defendants agree that by entering into this Stipulation, Plaintiffs have not waived

4 their pending motion to exclude Defendants' class experts to be heard by this Court on July 11, 2011. 6

7. Plaintiffs reserve the ability to reasonably refine Plaintiffs' July 6th supplementation no later than July 15, 2011 as to data or information produced on or after May 27, 2011, and Defendants reserve the ability to reasonably refine Defendants' July 18th 9 supplementation no later than 48 hours prior to the deposition of the respective Defendants' 10

Class Expert. 11

IT IS SO STIPULATED ON JUNE 14, 2011.

By____//S//__________________________ By____//S//__________________________

PROPOSED ORDER PURSUANT TO STIPULATION, IT IS SO ORDERED.

used to file this Stipulation and [Proposed] Order Regarding Class Discovery Schedule and Deadlines. In compliance with General Order 45.X.B. I hereby attest that counsel for all parties 5 concurred in this filing. 6

Dated: June 14, 2011 /s/ Steven H. Frankel_____

Steven H. Frankel

CERTIFICATION

I, Steven H. Frankel, am the ECF User whose identification and password are being

20110616

© 1992-2011 VersusLaw Inc.



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