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

Filing 16

STIPULATION and ORDER signed by William H Orrick, III on 4/7/2017 ORDERING that the deadline to file a joint brief regarding any discovery dispute is CONTINUED to 4/14/2017. (Washington, S)

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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

FILED
Apr 07, 2017
CLERK, U.S. DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA

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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.,

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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 TO CONTINUE
MOTION CUT-OFF RE:
DISCOVERY BY ONE WEEK; and
[PROPOSED] ORDER

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”) hereby agree to continue the deadline to

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file a joint brief regarding any discovery dispute as follows:

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

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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

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2.

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

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

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previous extension has been requested and granted. The joint brief regarding any

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discovery dispute is currently due on April 7, 2017.

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3.

WHEREAS the parties currently have a discovery dispute on which

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they are meeting and conferring, and preparing a joint statement for the Court. The

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parties are hopeful that they will resolve the issue but, if not, they request an

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additional week to file a joint discovery letter. No other case management dates

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will be impacted by this stipulation.

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4.

IT IS THEREFORE STIPULATED that the deadline to file a joint

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brief regarding any discovery dispute will be continued from to April 7, 2017 to

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April 14, 2017.

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Dated: April 7, 2017

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By: /s/ Laurence F. Padway
Laurence F. Padway
Attorneys for Plaintiff
Fadi G. Haddad, M.D.

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Law Offices of Laurence F. Padway

Dated: April 7, 2017

Burke, Williams & Sorensen, LLP

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

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

LA #4848-2814-0087 v1

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STIPULATION TO CONTINUE MOTION
CUT-OFF RE: DISCOVERY

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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.

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Dated: April 7, 2017
/S/ Laurence F. Padway
LAURENCE F. PADWAY
Attorneys for Plaintiff

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(PROPOSED) ORDER

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

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

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will be continued from to April 7, 2017 to April 14, 2017.

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IT IS SO ORDERED.
Dated: April 7, 2017

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

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

LA #4848-2814-0087 v1

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STIPULATION TO CONTINUE MOTION
CUT-OFF RE: DISCOVERY