The opinion of the court was delivered by: Garland E. Burrell, Jr. Senior United States District Judge
Stipulation and [Proposed] Order Continuing Dates Set in Scheduling
The Parties, by and through their respective counsel of record, hereby stipulate and agree as follows and respectfully request the Court approve and give effect to their stipulation:
1. On October 9, 2012, Ronald C. Schwarzkopf, of Schwarzkopf Law, substituted in as counsel for Plaintiff Alexandra Nicholson in place of her former attorney, Jon S. Allin, formerly of Schwarzkopf & Allin. At that time, Mr. Allin was winding up his practice and commencing a position with the California Attorney General's Office.
2. On Friday, December 7, 2012, Ralph E. Laird, of Mackenroth & Laird, LLP, substituted in as counsel for Plaintiff Alexandra Nicholson in place of her former attorney, Ronald C. Schwarzkopf.
3. On Monday, December 10th and Tuesday, December 11th of 2012, counsel for the parties discussed the dates and deadlines of the scheduling order at length in an effort to agree on new proposed dates and deadlines in order to allow additional time for disclosure of experts, for completion of discovery, and to file motions. In particular, counsel for the parties discussed additional discovery to take place before experts are disclosed, having the discovery completion deadline approximately two months before the deadline to hear motions, and having the Final Pretrial Conference take place at least two months after the deadline to hear motions.
4. The existing scheduling order dates are as follows: Initial expert witnesses disclosed by: December 31, 2012 Rebuttal experts disclosed by: January 31, 2013 All discovery completed by: April 1, 2013 Last hearing date for motions: June 3, 2013 Final Pretrial Conference: August 12, 2013 Trial to commence: October 22, 2013
NOW, THEREFORE, IT IS AGREED AND STIPULATED THAT good cause exists to continue the above events to the following dates:
Initial expert witnesses disclosed by: March 29, 2013 Rebuttal experts disclosed by: April 26, 2013 All discovery completed by: June 29, 2013 Last hearing date for motions: August 29, 2013 Final Pretrial Conference: November 11, 2013 Trial to commence: January 20, 2014
Dated: December 13, 2012 MACKENROTH & LAIRD LLP By: /s/ Ralph E. Laird Ralph E. Laird Attorneys for Plaintiff Alexandra Nicholson Dated: December 13, 2012 SNR DENTON US LLP By: /s/ Jeffry Butler (as authorized on 12/13/12) Jeffry Butler Attorneys for Defendant Allstate Insurance Company
IT IS SO ORDERED except since two of the proposed dates are court holidays and one is not an available hearing date for law and motion, the last hearing date for motions is rescheduled for August 26, 2013, at 9:00 a.m. and the pretrial conference is rescheduled for November 4, 2013, at 11:00 a.m. A joint pretrial statement shall be filed seven days prior to the hearing. The trial is rescheduled for January 28, 2014, at 9:00 a.m.
© 1992-2012 VersusLaw ...