Robinson v. Metropolitan Life Insurance Company

Filing 54

STIPULATION and ORDER signed by Judge John A. Mendez on 6/24/15 ORDERING that the following dates and deadlines as EXTENDED as follows: Expert Discovery Disclosure Deadline: 9/14/15, Rebuttal Expert Disclosure Deadline: 9/28/15, Discovery Cutoff: 1 1/16/15, Deadline for Filing of Motions for Summary Judgment: 12/16/15, Deadline for Hearing of Motions for Summary Judgment: 1/13/16, Joint Pretrial Statement Due: 2/12/16, Pre-Trial Conference SET for 2/19/2016 at 11:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez, Jury Trial SET for 3/28/2016 at 09:00 AM in Courtroom 6 (JAM) before Judge John A. Mendez. (Kastilahn, A)

1 Royal F. Oakes (SBN 080480)
[e-mail]
2 Michael A.S. Newman (SBN 205299)
[e-mail]
3 HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
4 Los Angeles, CA 90071-2043
Telephone: [phone]
5 Facsimile: 213-614-7399
6 Attorneys for Defendant
Metropolitan Life Insurance Company
7
8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11 DANIELA ROBINSON,
Plaintiff,
12
13

Case No. 2:12-cv-01373 JAM AC
STIPULATION TO CONTINUE
PRE-TRIAL AND TRIAL DATE

vs.

14 METROPOLITAN LIFE INSURANCE
COMPANY,
15
Defendants.
16
17
18
19
20
21
22
23
24
25
26
27
28
HINSHAW & CULBERTSON
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

36069689v1 0963669

1

Plaintiff Daniela Robinson and Defendant Metropolitan Life Insurance

2

Company, by and through their respective counsel, hereby stipulate to a brief

3

continuance of certain pre-trial dates and the trial date to accommodate the parties'

4

schedules and to promote efficiency and economy.

5

The parties have been actively attempting to schedule numerous depositions,

6

approximately 20, the majority of which will require travel involving multiple trips

7

to the Midwest and East Coast. To date, calendar conflicts have made it difficult to

8

schedule the depositions. In an effort to resolve these calendar conflicts and to save

9

unnecessary travel and expense, the parties have agreed to attempt to schedule a

10

single deposition of MetLife's “person most knowledgeable” regarding pertinent

11

subjects in the near future, to be followed by a mediation session, tentatively to be

12

held before the Honorable Raul Ramirez (Ret.).

13

To accommodate these agreements between the parties, and to ensure that

14

there is time following the mediation session should it not result in a resolution of

15

this matter, the parties request approximately an extension of approximately thirty

16

days of the following dates and deadlines:

17

Expert Discovery Disclosure Deadline:

18

2015)

August 14, 2015 (to September 14,

19
20
21
22

Rebuttal Expert Disclosure Deadline: August 28, 2015 (to September 28,
2015)
Discovery Cutoff: October 16, 2015 (to November 16, 2015)

23
24
25

Deadline for Filing of Motions for Summary Judgment : November 18, 2015
(to December 16, 2015)

26

Deadline for Hearing of Motions for Summary Judgment: December 16,

27

2015 (to January 13, 2016)

28
HINSHAW & CULBERTSON
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

1
36069689v1 0963669

1

Joint Pretrial Statement Due: January 22, 2016 (to February 12, 2016)

2
3
4

Pre-Trial Conference: January 29, 2016 (to February 19, 2016) at 11:00 a.m.;
Jury Trial: March 7, 2016 (to March 28, 2016) at 9:00 a.m.

5
6
7

DATED: June 22, 2015

8

DANIEL S. GLASS
By: /s/ Daniel S. Glass
Daniel S. Glass
Attorneys for Plaintiff
Daniela Robinson

9
10
11
12
13
14
15

HINSHAW & CULBERTSON LLP

DATED: June 22, 2015

By: /s/ Royal F. Oakes
Royal F. Oakes
Michael A.S. Newman
Attorneys for Defendant
Metropolitan Life Insurance Company

16
17
18
19
20
21
22
23
24
25
26
27
28
HINSHAW & CULBERTSON
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

2
36069689v1 0963669

1
2
3

ORDER
Pursuant to the above stipulation and good cause appearing therefor, the
Court orders the pre-trial dates and trial date continued as requested.

4
5

IT IS SO ORDERED.

6

DATED: 6/24/2015

7

/s/ John A. Mendez_____________________

8

United States District Court Judge

9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
HINSHAW & CULBERTSON
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

3
36069689v1 0963669