Reynolds et al v. Metropolitan Life Insurance Company

Filing 13

STIPULATION and ORDER signed by Judge John A. Mendez on 11/29/12 ORDERING as follows: The parties shall have until January 28, 2013 to complete mediation; The parties are excused from filing an updated joint status report by December 7, 2012; The parties shall have until February 4, 2013 to submit an updated joint status report concerning the outcome of the mediation. (Becknal, R)

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SEDGWICK LLP
REBECCA A. HULL Bar No. 99802
[e-mail]
MARK J. HANCOCK Bar No. 160662
[e-mail]
333 Bush Street, 30th Floor
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CATHY A. REYNOLDS 2008 REVOCABLE
TRUST; R.W. “SKIP” REYNOLDS,
TRUSTEE OF CATHY A. REYNOLDS 2008
REVOCABLE TRUST; RHYS HOSKINS,
Beneficiary of Cathy A. Reynolds 2008
Revocable Trust and heir of Cathy A. Reynolds,
Decedent; MELORIA HOSKINS, Beneficiary
of Cathy A. Reynolds 2008 Revocable Trust
and heir of Cathy A. Reynolds, Decedent;
ESTATE OF CATHY A. REYNOLDS; R. W.
“SKIP” REYNOLDS as Executor of the Estate
of Cathy A. Reynolds; and R. W. “SKIP”
REYNOLDS as Conservator of the Estate of
Cathy A. Reynolds,

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Case No. 2:12-cv-00417 JAM-DAD
STIPULATION AND ORDER TO
FURTHER CONTINUE MEDIATION
COMPLETION DEADLINE

Plaintiffs,
v.
METROPOLITAN LIFE INSURANCE
COMPANY,
Defendants.

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IT IS HEREBY STIPULATED AND AGREED by and between Plaintiffs and

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Defendant Metropolitan Life Insurance Company by and through their respective attorneys of

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record, as follows:

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SF/2580223v1

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STIPULATION AND [PROPOSED] ORDER TO FURTHER CONTINUE MEDIATION
COMPLETION DEADLINE

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Mediation had been scheduled to take place on October 4, 2012 before JAMS Mediator

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Judge Ellen Sickle James (Ret.). However, on October 12, 2012, the Court signed a stipulation

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and order extending the mediation completion deadline to November 27, 2012, and the status

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report-filing deadline to December 7, 2012, as a result of attorney scheduling issues arising after

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the mediation date had been selected. As the parties were preparing for the rescheduled

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mediation to be held before Judge James on November 27, 2012, the parties determined that both

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sides may have additional documents that should be produced and reviewed in advance of the

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mediation, and that such production and review could not occur prior to November 27, 2012.

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Accordingly, the parties agreed that it would be best to further postpone the mediation in order to

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maximize the likelihood that the mediation would be effective.

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At this time the parties seek an order that: (1) they be given approximately 60 days from

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November 27, 2012, or until January 28, 2013, to complete mediation; (2) they be excused from

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filing an updated joint status report by December 7, 2012; and (3) they be given until February 4,

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2013 to submit an updated joint status report concerning the outcome of the rescheduled

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mediation.

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IT IS SO STIPULATED.

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DATED: November 29, 2012

HELLER & HIBBERT

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By: /s/ Steven M. Heller (as authorized 11/29/12)
Steven M. Heller
Attorneys for Plaintiffs

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DATED: November 29, 2012

SEDGWICK LLP
By: /s/ Mark J. Hancock
Rebecca A. Hull
Mark J. Hancock
Attorneys for Defendant

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SF/2580223v1

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STIPULATION AND [PROPOSED] ORDER TO FURTHER CONTINUE MEDIATION
COMPLETION DEADLINE

ORDER

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Good cause appearing and pursuant to the above Joint Stipulation to Continue Mediation
Completion Deadline, it is HEREBY ORDERED as follows:

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1. The parties shall have until January 28, 2013 to complete mediation;

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2. The parties are excused from filing an updated joint status report by December 7, 2012;

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3. The parties shall have until February 4, 2013 to submit an updated joint status report

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concerning the outcome of the mediation.

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Date: 11/29/2012
/s/ John A. Mendez____________
JOHN A. MENDEZ
United States District Court Judge

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SF/2580223v1

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STIPULATION AND [PROPOSED] ORDER TO FURTHER CONTINUE MEDIATION
COMPLETION DEADLINE