Ramirez v. Metropolitan Life Insurance Company, et al,.

Filing 19

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 12/7/2018. The Court orders the existing pretrial dates and deadlines extended, as follows: Designation of expert witnesses: March 7, 2019; Designation of rebuttal expert witnesses and percipient discovery cutoff: April 8, 2019; and Last day for hearings on dispositive motions: May 31, 2019.(Andrews, P)

1 ROYAL F. OAKES (SBN 080480)
[e-mail]
2 MICHAEL A.S. NEWMAN (SBN 205299)
[e-mail]
3 Hinshaw & Culbertson LLP
633 West 5th Street, 47th Floor
4 Los Angeles, CA 90071-2043
Telephone: [phone]
5 Facsimile: 213-614-7399
6 Attorneys for Defendant
METROPOLITAN LIFE INSURANCE COMPANY
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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NAOMI RAMIREZ,
Plaintiff,

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vs.

METROPOLITAN LIFE INSURANCE
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GROUPS BENEFITS,
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Defendants.
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Case No. 2:17-cv-01561-KJMCKD
(Honorable Kimberly J. Mueller)
STIPULATION BY ALL
PARTIES TO REQUEST A 90DAY CONTINUANCE OF PRETRIAL DEADLINES; ORDER
Hearing Date: Not Set
Hearing Time: Not Set
Courtroom: 3
Complaint Filed: July 27, 2017

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HINSHAW & CULBERTSON LLP
633 West 5th Street
47th Floor
Los Angeles, CA 90071-2043
213-680-2800

STIPULATION BY ALL PARTIES TO REQUEST A 90-DAY CONTINUANCE OF PRE-TRIAL
DEADLINES; [PROPOSED] ORDER
Case No. 2:17-cv-01561-KJM-CKD
302916372v1 1005131

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It is hereby stipulated by and between attorneys of record for all parties:

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1.

On April 6, 2018 the Court in the above-entitled matter established the

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following deadlines: The expert designation deadline is December 7, 2018; the

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rebuttal expert designation deadline, and the percipient discovery deadline, are both

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January 7, 2019; and, the last day on which a dispositive motion may be heard is

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February 22, 2018.

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2.

The parties have diligently conducted discovery, but wish to participate

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in a mediation session, without the need for completing all remaining discovery,

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including approximately one dozen depositions, many involving testimony by

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physicians, which would all need to be completed during the upcoming holidays to

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comply with existing deadlines.

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3.

The parties also wish to pursue settlement possibilities without the need

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for filing and responding to dispositive motions. Based on the available line motion

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hearing dates, such motions would need to be filed by January 4, 2019.

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4.

The parties thus request respectfully request the continuance of the above

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deadlines by approximately 90 days, or to any dates thereafter convenient with the

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Court's calendar, to permit the parties to pursue settlement possibilities, and to avoid

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the necessity of extensive deposition testimony.

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DATED: December 4, 2018

Hinshaw & Culbertson LLP

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By: /s/ Royal F. Oakes
ROYAL F. OAKES
MICHAEL A.S. NEWMAN
Attorneys for Defendant
METROPOLITAN LIFE INSURANCE
COMPANY

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HINSHAW & CULBERTSON LLP
633 West 5th Street
47th Floor
Los Angeles, CA 90071-2043
213-680-2800

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STIPULATION BY ALL PARTIES TO REQUEST A 90-DAY CONTINUANCE OF PRE-TRIAL
DEADLINES; ORDER
Case No. 2:17-cv-01561-KJM-CKD
302916372v1 1005131

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DATED: December 4, 2018

Ortiz Law Group, P.C.
By: /s/ Jesse Ortiz
JESSE ORTIZ
NOLAN BERGGREN
Attorneys for Plaintiff
NAOMI RAMIREZ

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HINSHAW & CULBERTSON LLP
633 West 5th Street
47th Floor
Los Angeles, CA 90071-2043
213-680-2800

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STIPULATION BY ALL PARTIES TO REQUEST A 90-DAY CONTINUANCE OF PRE-TRIAL
DEADLINES; ORDER
Case No. 2:17-cv-01561-KJM-CKD
302916372v1 1005131

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ORDER

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For good cause appearing therefor, the Court orders the existing pretrial dates

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and deadlines extended, as follows:

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1. Designation of expert witnesses: March 7, 2019.

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2. Designation of rebuttal expert witnesses and percipient discovery cut

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off: April 8, 2019.
3. Last day for hearings on dispositive motions: May 31, 2019.
DATED: December 7, 2018.

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UNITED STATES DISTRICT JUDGE

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HINSHAW & CULBERTSON LLP
633 West 5th Street
47th Floor
Los Angeles, CA 90071-2043
213-680-2800

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STIPULATION BY ALL PARTIES TO REQUEST A 90-DAY CONTINUANCE OF PRE-TRIAL
DEADLINES; ORDER
Case No. 2:17-cv-01561-KJM-CKD
302916372v1 1005131