Garcia v. Standard Life Insurance Company

Filing 26

STIPULATION and ORDER signed by Senior Judge William B. Shubb on 3/11/15. Garcia's response to the motion for summary judgment is due by 3/25/15. Standard's reply due by 4/9/15. (Manzer, C)

1
2
3
4
5
6

WARREN H. NELSON, JR., # 104744
A PROFESSIONAL CORPORATION
6161 El Cajon Blvd., # 273
San Diego, CA 92115
Telephone: [phone]
Facsimile: 619 501 7948
Email: [e-mail]
Attorney for Defendant
Standard Insurance Company

7
8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA

10
11

KATHLEEN GARCIA,
Plaintiff,

12
13

vs.

14
15

STANDARD INSURANCE
COMPANY, et al.

16
17
18
19

Defendants.

)
)
)
)
)
)
)
)
)
)
)
)
)
)
)

Case No.: 2:13-cv-02164-WBS-CKD
STIPULATION AND [PROPOSED]
ORDER RE BRIEFING SCHEDULE
ON STANDARD INSURANCE
COMPANY’S PENDING MOTION
FOR PARTIAL SUMMARY
JUDGMENT
No hearing set or required.
Before the Honorable William B.
Shubb, Judge

Plaintiff Kathleen Garcia and Defendant Standard Insurance Company

20

(“Standard”) conferred upon the date to be selected for the hearing on Standard’s

21

Motion for Partial Summary Judgment, filed February 22, 2015 (the “Motion”

22

(PACER Docs 22-23)). Prior to filing the Motion, the last date available for the

23

hearing, as communicated by the Courtroom Deputy, was April 20, 2015. Subject

24

to the Court’s approval, Standard and Garcia stipulated and agreed as follows in

25

connection with selecting April 20, 2015, as the hearing date on the Motion, so that

26

(i) Standard and Garcia would have additional time to brief (beyond the dates

27

specified in Local Rule 230(b)-(c)), and, (ii) the Court would have additional time

28

STIP/PROP ORDER TO ADJUST SJ BRIEFING SCHEDULE – 2:13-cv-02164-WBS-CKD - 1

1
2
3

to consider the Motion prior to the April 20 hearing:
1. The Response of Garcia to the Motion will be due on or before March 25,
2015.

4

2. The Reply of Standard on the Motion will be due on or before April 9,

5

2015. (Standard had originally agreed to file the Reply on or before

6

April 10 but has adjusted its own due date, which in no way impacts the

7

obligations of Garcia, back one day to April 9, to give the Court an extra

8

day to consider the Motion following completion of all filing.)

9

3. Aside from adjusting the due dates of the Response and Reply briefing

10

(and the due dates of the filing of all papers related to the same) of the

11

Motion, no other deadline is hereby changed.

12
13

4. Standard and Garcia respectfully point out that the foregoing schedule
will also provide additional time to the Court to consider the Motion.

14

IT IS SO STIPULATED.

15

Dated: March 9, 2015
/s/ Warren H. Nelson, Jr.
WARREN H. NELSON, JR.
A PROFESSIONAL CORPORATION
6161 El Cajon Boulevard, # 273
San Diego, CA 92115

16
17
18

Attorney for Defendant
STANDARD INSURANCE COMPANY

19
20
21

IT IS SO STIPULATED.
Dated: March 9, 2015

22
23
24
25
26
27

/s/ Dan Rainsbury
Dan Rainsbury
DAVID ALLEN & ASSOCIATES
5230 Folsom Boulevard
Sacramento, CA 95819
Attorneys for Plaintiff
KATHLEEN GARCIA

28

STIP/PROP ORDER TO ADJUST SJ BRIEFING SCHEDULE – 2:13-cv-02164-WBS-CKD - 2

1

IT IS SO ORDERED.

2

Dated: March 11, 2015

3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

DOCKET No. 2:13-cv-02164-WBS-CKD

STIP/PROP ORDER TO ADJUST SJ BRIEFING SCHEDULE – 2:13-cv-02164-WBS-CKD - 3

1

Kathleen Garcia v. Standard Insurance Company, et al.

2

PROOF OF ELECTRONIC SERVICE VIA CM/ECF

3

I, Warren H. Nelson, Jr., the undersigned, hereby certify and declare under

4

penalty of perjury that I am over the age of 18 years and am not a party to this

5

action. My business address is Warren H. Nelson, Jr., A Professional Corporation,

6

6161 El Cajon Blvd., # 273, San Diego, CA 92115, telephone [phone],

7

facsimile [phone]. On the 11th day of March 2015, I electronically filed in

8

the above action the following document titled exactly:

9

11

STIPULATION AND [PROPOSED] ORDER RE BRIEFING SCHEDULE ON
STANDARD INSURANCE COMPANY’S PENDING MOTION FOR PARTIAL
SUMMARY JUDGMENT
I have consulted the PACER record for this case. Lead counsel, counsel to be

12

noticed, is there currently specified as Dan Rainsbury, Esq. The foregoing

13

document will therefore automatically be electronically served on Mr. Rainsbury

14

upon submission to the Court on its CM/ECF System.

10

15
16

I declare under penalty of perjury that the foregoing is true and correct.
Executed this 11th day of March 2015 at San Diego, California.

17
18

_/s/ Warren H. Nelson, Jr._
Warren H. Nelson, Jr.

19
20
21
22
23
24
25
26
27
28

STIP/PROP ORDER TO ADJUST SJ BRIEFING SCHEDULE – 2:13-cv-02164-WBS-CKD - 4