Dickson v. Liberty Life Assurance Company of Boston

Filing 14

STIPULATION and ORDER signed by Magistrate Judge Allison Claire on 10/7/16: The date by which Plaintiff's responses to Liberty's interrogatories, set one, and request for production of documents, set one, must be served has been ex tended, and the responses shall be due to be served on or before November 23, 2016; further, the date by which Liberty's responses to Plaintiff's interrogatories, set one, and request for production of documents, set one, must be served has been extended, and the responses shall be due to be served on or before November 23, 2016. (Kaminski, H)

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1 2 3 4 5 6 A Professional Corporation Redwood City Ropers Majeski Kohn & Bentley 7 PAMELA E. COGAN (SBN 105089) STACY M. TUCKER (SBN 218942) BLAKE J. RUSSUM (SBN 258031) ROPERS, MAJESKI, KOHN & BENTLEY 1001 Marshall Street, Suite 500 Redwood City, CA 94063-2052 Telephone: (650) 364-8200 Facsimile: (650) 780-1701 Email: pamela.cogan@rmkb.com; stacy.tucker@rmkb.com; blake.russum@rmkb.com Attorneys for Defendant LIBERTY LIFE ASSURANCE COMPANY OF BOSTON 8 UNITED STATES DISTRICT COURT 9 EASTERN DISTRICT OF CALIFORNIA 10 11 CHRISTY DICKSON, 12 Plaintiff, 13 v. 14 Case No. 2:16-cv-00900-KJM-AC STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR TO RESPOND TO WRITTEN DISCOVERY LIBERTY LIFE ASSURANCE COMPANY OF BOSTON, a corporation, and DOES 1-10, inclusive, 15 16 Defendants. 17 Pursuant to Local Rule 144(a), Plaintiff Christy Dickson (“Plaintiff”) and Defendant 18 19 Liberty Life Assurance Company of Boston’s (“Liberty”) hereby submit the stipulation set forth 20 herein for the Court’s approval: 21 WHEREAS, Plaintiff’s responses to Liberty’s interrogatories, set one, and request for 22 production of documents, set one, were initially due to be served on or before September 28, 23 2016; 24 WHEREAS, Liberty’s responses to Plaintiff’s interrogatories, set one, and request for 25 production of documents, set one, were initially due to be served on or before September 30, 26 2016; 27 28 WHEREAS, Plaintiff and Liberty have agreed to participate in private mediation before mediator Vivien Williamson, which is scheduled for November 9, 2016; 4816-2937-2474.1 STIPULATION EXTENDING TIME TO RESPOND TO DISCOVERY-CASE NO.: CV-00900-KJM-AC 1 WHEREAS, Plaintiff and Liberty agree that it would be a more efficient use of time and 2 resources to respond to the propounded written discovery after the parties have engaged in 3 settlement negotiations at the pending mediation set for November 9, 2016; 4 WHEREAS, Plaintiff and Liberty agree that the responses to the written discovery 5 propounded to each of them shall be due to be served on or before November 23, 2016, should 6 the matter not resolve at the November 9, 2016 mediation; A Professional Corporation Redwood City Ropers Majeski Kohn & Bentley 7 THEREFORE, IT IS HEREBY STIPULATED by and between Plaintiff Christy Dickson 8 and Defendant Liberty Life Assurance Company of Boston that the date by which Plaintiff’s 9 responses to Liberty’s interrogatories, set one, and request for production of documents, set one, 10 must be served has been extended, and the responses shall be due to be served on or before 11 November 23, 2016; further, the date by which Liberty’s responses to Plaintiff’s interrogatories, 12 set one, and request for production of documents, set one, must be served has been extended, and 13 the responses shall be due to be served on or before November 23, 2016; 14 15 IT IS SO STIPULATED. Dated: October 3, 2016 DARRASLAW 16 17 By:/s/ Suan B. Grabarsky Frank N. Darras Susan B. Grabarsky Attorneys for Plaintiff CHRISTY DICKSON 18 19 20 Dated: October 3, 2016 ROPERS, MAJESKI, KOHN & BENTLEY 21 22 By:/s/ Stacy M. Tucker PAMELA E. COGAN STACY M. TUCKER BLAKE J. RUSSUM Attorneys for Defendant LIBERTY LIFE ASSURANCE COMPANY OF BOSTON 23 24 25 26 27 28 4816-2937-2474.1 -2- STIPULATION EXTENDING TIME TO RESPOND TO DISCOVERY-CASE NO.: CV-00900-KJM-AC 1 [PROPOSED] ORDER 2 3 4 Pursuant to the Parties’ Stipulation, IT IS SO ORDERED. Dated: October 7, 2016 5 6 A Professional Corporation Redwood City Ropers Majeski Kohn & Bentley 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4816-2937-2474.1 -3- STIPULATION EXTENDING TIME TO RESPOND TO DISCOVERY-CASE NO.: CV-00900-KJM-AC

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