Filed: Dec. 31, 2014
Latest Update: Dec. 31, 2014
Summary: STIPULATION BETWEEN PLAINTIFF TITAN INDEMNITY COMPANY AND DEFENDANT KATRINA RAPP REGARDING COORDINATION OF DEPOSITIONS, AND ORDER WILLIAM ALSUP, District Judge. IT IS HEREBY STIPULATED by and between plaintiff Titan Indemnity Company, by and through its attorney of record, Galina Kletser Jakobson, Esq. of Selman Breitman LLP, and defendant Katrina Rapp, by and through her attorney of record, Martin T. Reilley, Esq. of Krankemann Law Offices, pursuant to Federal Rules of Civil Procedure, Rule 2
Summary: STIPULATION BETWEEN PLAINTIFF TITAN INDEMNITY COMPANY AND DEFENDANT KATRINA RAPP REGARDING COORDINATION OF DEPOSITIONS, AND ORDER WILLIAM ALSUP, District Judge. IT IS HEREBY STIPULATED by and between plaintiff Titan Indemnity Company, by and through its attorney of record, Galina Kletser Jakobson, Esq. of Selman Breitman LLP, and defendant Katrina Rapp, by and through her attorney of record, Martin T. Reilley, Esq. of Krankemann Law Offices, pursuant to Federal Rules of Civil Procedure, Rule 29..
More
STIPULATION BETWEEN PLAINTIFF TITAN INDEMNITY COMPANY AND DEFENDANT KATRINA RAPP REGARDING COORDINATION OF DEPOSITIONS, AND ORDER
WILLIAM ALSUP, District Judge.
IT IS HEREBY STIPULATED by and between plaintiff Titan Indemnity Company, by and through its attorney of record, Galina Kletser Jakobson, Esq. of Selman Breitman LLP, and defendant Katrina Rapp, by and through her attorney of record, Martin T. Reilley, Esq. of Krankemann Law Offices, pursuant to Federal Rules of Civil Procedure, Rule 29 authorizing the parties to stipulate to modify procedures regarding discovery, except in the extension of deadlines, and in the interest of maximizing efficiency, and reducing the time and costs necessary to complete discovery in this action:
1. That the depositions of Jose Hermosillo, Sr., Jose Hermosillo, Jr., Fernando Hermosillo, Eugene Roberson, and Katrina Rapp may be taken simultaneously with, and in conjunction with the depositions of the same individuals in the State Court action of Katrina Rapp v. A Plus Towing, et al., Superior Court of California, County of Sonoma, Case No. 255299. The stipulating parties agree that the aforementioned five depositions shall be taken pursuant the California Code of Civil Procedure provisions that govern before whom depositions may be taken, the time and place of depositions, and the notice and manner of depositions.
2. The stipulating parties agree that the aforementioned five depositions may be used for all pretrial and trial-related purposes in this, the above entitled federal court action, without objection by any party based on the fact that the depositions were taken pursuant to the California Code of Civil Procedure.
3. The stipulating parties preserve all other objections and rights pursuant to the Federal Rules of Civil Procedure, the Federal Rules of Evidence, the California Code of Civil Procedure, and the California Rules of Evidence to the use of these depositions at trial based on relevance and privilege.
ORDER
Upon Stipulation of the parties and good cause appearing therefore,
IT IS SO ORDERED.
