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Philip Rudolph Johnson v. American Casualty Company of Reading

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


October 4, 2011

PHILIP RUDOLPH JOHNSON,
PLAINTIFF,
v.
AMERICAN CASUALTY COMPANY OF READING PA, A PENNSYLVANIA CORPORATION; DOES 1-100,

The opinion of the court was delivered by: The Honorable Samuel Conti District Judge

Thomas P. Burke, II -- (Arizona State Bar #009631 [pro hac vice]) BURKE PANZARELLA RICH 2 2198 E. Camelback Road, Suite 375 Phoenix, AZ 85016 (602) 222-4848 4 (602) 222-4858 -- FAX Email: minuteentries@bprlaw.com 5 6 Thomas G. Lewellyn - (California State Bar #111733) 1151 Harbor Bay Parkway, Suite 142 7 Alameda, CA 94502 (510) 337-1600 (510) 337-7904 -- FAX Email: tlewellynlaw@sbcglobal.net John E. Peer, Bar No. 95978 Katy A. Nelson, Bar No. 173759 WOOLLS & PEER A Professional Corporation One Wilshire Boulevard, 22nd Floor Los Angeles, California 90017 Telephone: (213) 629-1600 Facsimile: (213) 629-1660 jpeer@woollspeer.com, knelson@woollspeer.com Attorneys for Defendant American Casualty Company of Reading, PA Attorneys for Plaintiff

STIPULATION AND ORDER RE ENLARGING TIME FOR PLAINTIFF TO RESPONND TO MOTIONS IN LIMINE Trial Date: 03/05/12

Assigned to the Hon. Samuel Conti Pretrial conference: 02/24/12 Defendant. Discovery Cutoff Date: 9/30/11

Defendants have filed six Motions in Limine [Docket #73, #74, #75, #76, #77 2 and #78]. The parties stipulate that Plaintiff Johnson may have until October 14, 2011 to 3 respond to those motions based on the following good reasons. 4

First, the parties have cooperatively worked toward completion of depositions which have involved considerable effort and travel every week for the past month, with 7 the last deposition completed just yesterday (Sept 29). Second, the parties are scheduled 8 to participate in a private mediation next week (Oct 6), and effort is now directed 9 toward the mediation. Third, the court has reset trial and the hearing on pending Motions in Limine (and the Pretrial Conference) by approximately four months.

(Docket #86). Thus, the short extension is reasonable.

Accordingly, counsel respectfully request an order extending the deadline for plaintiff to respond to defendants' Motions in Limine to October 14, 2011. 15

IT IS HEREBY ORDERED that this stipulation is hereby approved and adopted as the order of the court.

20111004

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