Haddad, M.D. v. SMG Long Term Disability Plan et al

Filing 132

STIPULATION and ORDER signed by William H Orrick, III on 6/25/2021 EXTENDING the parties time to either submit a joint proposed form of judgment or provide the Court their respective versions of the judgment.(Becknal, R)

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LAW OFFICES OF LAURENCE F. PADWAY
Laurence F. Padway (SBN 89314)
2911 Lincoln Avenue
Alameda, CA 94501
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff Fadi G. Haddad, M.D.
Michael B. Bernacchi (SBN 163657)
E-mail: [e-mail]
BURKE, WILLIAMS & SORENSEN, LLP
444 South Flower Street, Suite 2400
Los Angeles, CA 90071-2953
Tel: [phone]
Fax: [phone]
Attorneys for Defendant Hartford Life and
Accident Insurance Company

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO

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FADI G. HADDAD, M.D.,
Plaintiff,

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v.

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SMG LONG TERM DISABILITY
PLAN, AND HARTFORD LIFE
AND ACCIDENT INSURANCE
COMPANY,

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Case No. 2:16-cv-01700-WHO
STIPULATION FOR BRIEF
EXTENSION OF TIME TO
SUBMIT AGREED-TO PROPOSED
FORM OF JUDGMENT

Defendants.

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Plaintiff Fadi G. Haddad, M.D. (“Plaintiff” ) and Defendant Hartford Life and

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Accident Insurance Company (“Hartford” ), through counsel, hereby stipulate and

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request a brief extension based on the following:

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1.

On June 15, 2021, the Court held a status conference and ordered the

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parties to submit an agreed-to proposed form of judgment (or a redlined version

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reflecting any disagreements regarding the terms) by June 24, 2021 for review.

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[Dkt. 129]

B URKE , W I LLIAMS &
S ORENS EN , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

LA #4828-6723-2240 v1

STIPULATION FOR BRIEF EXTENSION OF
TIME TO SUBMIT AGREED-TO PROPOSED
FORM OF JUDGMENT

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2.

The parties have finalized the PDE settlement and exchanged proposed

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forms of a final judgment. However, Plaintiff’ counsel is undergoing a medical
s

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procedure today and the parties have not had a chance to finish the meet and confer

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over the proposed judgment. Accordingly, by tomorrow (June 25, 2021) at 5:00

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p.m., the parties will either submit a joint proposed form of judgment or provide the

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Court their respective versions of the judgment.

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IT IS SO STIPULATED.

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Dated: June 24, 2021

Law Offices of Laurence F. Padway

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By: /s/ Laurence F. Padway
[As authorized on June 24, 2021]
Laurence F. Padway
Attorneys for Plaintiff
Fadi G. Haddad, M.D.

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Dated: June 24, 2021

Burke, Williams & Sorensen, LLP

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By: /s/ Michael B. Bernacchi
Michael B. Bernacchi
Attorneys for Defendant
Hartford Life and Accident Insurance
Company

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ORDER

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Good cause appearing, IT IS SO ORDERED.

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Dated: ________________
June 25, 2021

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_________________________________
Honorable William H. Orrick
United States District Judge

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B URKE , W I LLIAMS &
S ORENS EN , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

LA #4828-6723-2240 v1

-2-

STIPULATION FOR BRIEF EXTENSION OF
TIME TO SUBMIT AGREED-TO PROPOSED
FORM OF JUDGMENT