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 to 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. The parties have proceeded with additional written discovery and productions of documents and have completed the depositions of Plaintiff and an Allstate employee, Jess Molina. Two depositions are currently scheduled for March 22nd, and additional depositions are anticipated and would preferably be completed before the initial expert disclosure date which is currently March 29, 2013. One of the witnesses had a death in his family which caused continuance of his deposition, which remains to be scheduled. The parties have agreed to continue the dates for the initial expert witness disclosure and the rebuttal expert disclosure as set forth below. The parties believe continuance of these disclosure dates will not impact any of the other dates currently set in the scheduling order.
4. The existing scheduling order dates are as follows: 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 26, 2013 Final Pretrial Conference: November 4, 2013 Trial to commence: January 28, 2014
NOW, THEREFORE, IT IS AGREED AND STIPULATED THAT good cause exists to continue to the dates for initial expert witnesses disclosure and rebuttal expert disclosure to the following dates:
Initial expert witnesses disclosed by: April 26, 2013 Rebuttal experts disclosed by: May 24, 2013 The date for completion of discovery, the last date for motions, the date for the Final Pretrial Conference, and the date to commence Trial shall remain the same as set forth herein above. Dated: March 18, 2012 MACKENROTH & LAIRD LLP
By: /s/ Ralph E. Laird Ralph E. Laird Attorneys for Plaintiff Alexandra Nicholson Dated: March 18, 2012 SNR DENTON US LLP By: /s/ Jeffry Butler (as authorized on 3/18/12) Jeffry Butler Attorneys for Defendant Allstate Insurance Company
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