Hamel v. Quebecor World Inc. Long Term Disability Plan, et al

Filing 28

STIPULATION to Continue Discovery; ORDER - Discovery cutoff extended from 4/30/12 to 6/6/2012. signed by Magistrate Judge Barbara A. McAuliffe on 2/21/2012. (Herman, H)

1 RUSSELL G. PETTI, State Bar No. 137160
THE LAW OFFICES OF RUSSELL G. PETTI
2 466 Foothill Blvd., # 389
La Canada, California 91011
3 818 952-2168Telephone
818 952-2186 Facsimile
4 Email: [e-mail]
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Attorneys for Plaintiff Paul A. Hamel

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA - FRESNO DIVISION

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11 PAUL A. HAMEL,

CASE NO: 1:11-CV-00148-LJO-BAM

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STIPULATION TO CONTINUE
DISCOVERY; ORDER

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)
)
)
Plaintiff,
)
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VS.
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QUEBECOR WORLD INC. LONG
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TERM DISABILITY PLAN and
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HARTFORD LIFE AND ACCIDENT )
INSURANCE COMPANY,
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Defendants.
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_________________________________)

Current Discovery Cutoff:
April 30, 2012
Requested Discovery Cutoff:
June 6, 2012

Plaintiff Paul Hamel and defendants Quebecor World Inc. Long Term Disability
Plan (hereinafter “the LTD Plan”) and Hartford Life and Accident Insurance Company
(hereinafter “Hartford”), hereby Stipulate to the following:
1.

Plaintiff has served written discovery in this matter and Hartford has

responded. The parties have a significant dispute regarding the adequacy of Hartford’s
responses;
2.

The parties have agreed to put this discovery dispute on hold until after

mediating this case before the Honorable Barbara A. McCauliffe, the assigned Magistrate
Judge for this case;
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STIPULATION TO CONTINUE DISCOVERY CUTOFF; Case No. 1:11-CV-00148-LJO-BAM

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3.

However the earliest date that could be scheduled which conformed to the

2 calendars of counsel and the Court was March 1, 2012. This risks that the parties may
3 not be able to resolve their discovery dispute, which might involve judicial intervention,
4 and take whatever follow on discovery might be required by the current discovery cutoff
5 of April 20, 2012;
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4.

As such, the parties respectfully request that, in aid of settlement, the current

7 discovery cutoff date be extended from April 30, 2012 to June 6, 2012.
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IT IS SO STIPULATED

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11 Dated: February 17, 2012

Dated: February 17, 2012

12 RUSSELL G. PETTI
The Law Offices of Russell G. Petti
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MICHAEL B. BERNACCHI
KRISTIN KYLE DE BAUTISTA
Burke, Williams & Sorensen, LLP

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By: /s/ Russell G. Petti
Russell G. Petti
Attorneys for Plaintiff Paul Hamel

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By: /s/ Kristin Kyle De Bautista
Michael B. Bernacchi
Kristin Kyle De Bautista
Attorneys for Defendants
Quebecor World Inc. Long Term
Disability Plan and Hartford Life and
Accident Insurance Company
ORDER

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Based on the Stipulation of the Parties and for Good Cause Shown, the

22 discovery cutoff in this case is extended from April 30, 2012 to June 6, 2012.
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24 IT IS SO ORDERED.
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26 Dated:
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February 21, 2012

/s/ Barbara A. McAuliffe
UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO CONTINUE DISCOVERY CUTOFF; Case No. 1:11-CV-00148-LJO-BAM