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

Filing 14

STIPULATION and ORDER signed by William H Orrick, III on 2/28/2017 ORDERING the Discovery CONTINUED to 4/7/2017. (Washington, S) Modified on 3/1/2017 (Washington, S).

1
2
3
4
5
6
7
8
9
10

LAW OFFICES OF LAURENCE F. PADWAY
Laurence F. Padway (SBN 89314)
1516 Oak Street, Suite 109
Alameda, CA 94501
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff Fadi G. Haddad, M.D.
Michael B. Bernacchi (SBN 163657)
E-mail: [e-mail]
Cindy Mekari (SBN 272465)
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

11
12

UNITED STATES DISTRICT COURT

13

EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO

14
15

FADI G. HADDAD, M.D.,

16

Plaintiff,

17

v.

18

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

19
20

Case No. 2:16-cv-01700-WHO
STIPULATION TO CONTINUE
MOTION CUT-OFF RE:
DISCOVERY BY SIX WEEKS; and
ORDER

Defendants.

21
22
23

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

24

Accident Insurance Company (“Hartford”) hereby agree to continue the deadline to

25

file a joint brief regarding any discovery dispute as follows:

26
27
28
B URKE , W ILLIAMS &
S ORENSEN , LLP
ATTORNEYS AT LAW
LOS ANGELES

1.

WHEREAS, under Local Rule 37-3 discovery motions/briefs must be

filed within 7 days after the discovery cut-off.
LA #4848-2814-0087 v1

STIPULATION TO CONTINUE MOTION
CUT-OFF RE: DISCOVERY

1
2

2.

WHEREAS, the discovery cut-off in this case was February 24, 2017,

requiring any briefing regarding discovery disputes be filed by March 3, 2017.

3
4

3.

WHEREAS the parties currently have a discovery dispute which they

5

are meeting and conferring over. The parties hope to resolve the issue but, if not,

6

they request six weeks to file a joint discovery brief. The extra-time is needed both

7

because the dispute itself has only recently arisen and thus the parties need more

8

time to meet and confer and Plaintiff’s counsel is undergoing a medical procedure

9

in early March and will likely not be able to devote time to discovery issues while

10

he is recuperating. No other case management dates will be impacted by this

11

stipulation.

12
13

4.

IT IS THEREFORE STIPULATED that the deadline to file a joint

14

brief regarding any discovery dispute will be continued from February 24, 2017 to

15

April 7, 2017.

16
17
18

Dated: February 28, 2017

19

Law Offices of Laurence F. Padway
By: /s/ Laurence F. Padway
[As authorized on
Laurence F. Padway
Attorneys for Plaintiff
Fadi G. Haddad, M.D.

20
21
22
23

Dated: February 28, 2017

24

Burke, Williams & Sorensen, LLP
By: /s/ Michael B. Bernacchi
Michael B. Bernacchi
Cindy Mekari
Attorneys for Defendant
Hartford Life and Accident Insurance
Company

25
26
27
28
B URKE , W ILLIAMS &
S ORENSEN , LLP
ATTORNEYS AT LAW
LOS ANGELES

LA #4848-2814-0087 v1

-2-

STIPULATION TO CONTINUE MOTION
CUT-OFF RE: DISCOVERY

1
2
3

ATTESTATION PURSUANT TO GENERAL ORDER 45
I, Laurence F. Padway, attest that concurrence in the filing of this document
has been obtained from the other Signatory.

4
5

Dated: February 28, 2017
/S/ Laurence F. Padway
LAURENCE F. PADWAY
Attorneys for Plaintiff

6
7
8
9

ORDER

10
11

Pursuant to stipulation, and good cause appearing, IT IS HEREBY

12

ORDERED that the deadline to file a joint brief regarding any discovery dispute

13

will be continued from February 24, 2017 to April 7, 2017.

14
15
16

IT IS SO ORDERED.
Dated: February 28, 2017

17

________________________________
Hon. William H. Orrick III
United States District Judge

18
19
20
21
22
23
24
25
26
27
28
B URKE , W ILLIAMS &
S ORENSEN , LLP
ATTORNEYS AT LAW
LOS ANGELES

LA #4848-2814-0087 v1

-3-

STIPULATION TO CONTINUE MOTION
CUT-OFF RE: DISCOVERY