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STIPULATION TO EXTEND TIME TO DESIGNATE EXPERT WITNESSES

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Jeffrey H. Lowenthal (State Bar No. 111763)

Edward Egan Smith (State Bar No. 169792)

Lisa Marie Williams (State Bar No. 226360)

STEYER LOWENTHAL BOODROOKAS 

 ALVAREZ & SMITH LLP

One California Street, Third Floor

San Francisco, California 94111

Telephone: (415) 421-3400

Facsimile: (415) 421-2234

Attorneys for Defendant

North American Title Company, Inc.

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA - SACRAMENTO DIVISION

KEITH T. TOWNS,

Plaintiff,

vs.

AMERIQUEST MORTGAGE COMPANY,

TOWN AND COUNTRY TITLE SERVICES,

INC., NORTH AMERICAN TITLE

COMPANY, and DOES 1 TO 10, inclusive,

Defendants.

 

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Case No. S-04-1855 FCD/PAN

STIPULATION TO EXTEND TIME TO

DESIGNATE EXPERT WITNESSES

Case 2:04-cv-01855-KJM-EFB Document 14 Filed 09/12/05 Page 1 of 3
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STIPULATION TO EXTEND TIME TO DESIGNATE EXPERT WITNESSES

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Plaintiff Keith T. Towns, defendant Ameriquest Mortgage Company, defendant Town &

Country Title Services, Inc., and defendant North American Title Company, hereby enter into

the following stipulation:

RECITALS

WHEREAS, according to the December 30, 2004 Pretrial Scheduling Order, the last day to

designate expert witnesses is currently set for September 9, 2005, and the last day to designate

rebuttal expert witnesses is currently set for September 30, 2005;

WHEREAS, an extension of time to allow all parties an additional thirty days to designate

expert witnesses will not unduly delay the proceedings in this Court;

STIPULATION

NOW, THEREFORE, plaintiff and defendants hereby stipulate by and through their

respective counsel, as follows: 

1. Plaintiff and defendants stipulate to extend the time within which all parties may

designate in writing the expert witnesses they propose to tender at trial to October 14, 2005; and

2. Plaintiff and defendants further stipulate to extend the time within which all parties

may designate rebuttal expert witnesses to October 28, 2005.

Dated: September __, 2005 LEWIS N. NELSON, ATTORNEY AT LAW

By: /s/ - Lewis N. Nelson 

Lewis N. Nelson

Attorney for Plaintiff Keith T. Towns

/ / /

/ / /

/ / /

Dated: September __, 2005 BUCHALTER NEMER

A PROFESSIONAL CORPORATION

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STIPULATION TO EXTEND TIME TO DESIGNATE EXPERT WITNESSES

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By: /s/ - Mia S. Blackler 

Mia S. Blackler

Attorneys for Defendants Ameriquest

Mortgage Company and Town & Country

Title Services, Inc.

Dated: September __, 2005 STEYER LOWENTHAL BOODROOKAS 

 ALVAREZ & SMITH LLP

By: /s/ - Lisa Marie Williams 

Lisa Marie Williams

Attorneys for Defendant North American

Title Company

ORDER

Although, the foregoing stipulation does not clearly state the basis on which good cause

exists the extension requested does not effect all other dates set in this action, therefore, IT IS

HEREBY ORDERED THAT,

1. The deadline for all parties to designate expert witnesses shall be October 14, 2005;

and

2. The deadline for all parties to designate rebuttal expert witness shall be 

October 28, 2005.

3. The parties shall review paragraph XI of the Court’s Pretrial Scheduling Order,

filed January 3, 2005 prior to any future requests for extension of deadlines.

Dated: September 12, 2005 /s/ Frank C. Damrell Jr. 

The Honorable Frank C. Damrell, Jr.

United States District Judge

Case 2:04-cv-01855-KJM-EFB Document 14 Filed 09/12/05 Page 3 of 3