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

Filing 21

STIPULATION and ORDER signed by District Judge Kimberly J. Mueller on 2/5/19 EXTENDING the existing pretrial dates and deadlines as follows: Designation of Expert Witnesses: 5/7/19. Designation of Rebuttal Expert Witnesses and Percipient Discovery Cut Off: 6/8/19. Last day for hearings on Dispositive Motions: 8/9/19 at 10:00 a.m. in Courtroom No. 3. (Coll, A)

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

10 NAOMI RAMIREZ,
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Plaintiff,
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vs.

Case No. 2:17-cv-01561-KJMCKD
(Honorable Kimberly J. Mueller)

13 METROPOLITAN LIFE INSURANCE
14 COMPANY and FARMERS AGENTS
GROUPS BENEFITS,

STIPULATION BY ALL
PARTIES TO REQUEST A 60DAY CONTINUANCE OF PRETRIAL DEADLINES; ORDER

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Hearing Date: Not Set
Hearing Time: Not Set
Courtroom: 3

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Complaint Filed: July 27, 2017

Defendants.

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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 60-DAY CONTINUANCE OF PRE-TRIAL
DEADLINES; 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 was December 7, 2018; the

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

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

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February 22, 2018.

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2.

On December 7, 2018, following submission of a request by the parties

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to the Court for a continuance of deadlines in order to pursue settlement prospects,

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the Court set the expert witness designation deadline as March 7, 2019, the rebuttal

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expert designation and percipient discovery cutoff as April 8, 2019, and the last day

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for hearings on dispositive motions as May 31, 2019.

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3.

Although the parties have diligently conducted discovery, they wish to

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attend a mediation session without engaging in extensive discovery and possible

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motion practice required by the existing deadlines. A mediation session will take

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place on March 12, 2019, at the Sacramento, California office of mediator Douglas

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de Vries.

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4.

The parties thus request respectfully request the continuance of the above

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deadlines by an additional 60 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 and possible motion practice.

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

DATED: January 31, 2019

HINSHAW & CULBERTSON LLP
By: /s/ Royal F. Oakes
ROYAL F. OAKES
MICHAEL A.S. NEWMAN
Attorneys for Defendant
METROPOLITAN LIFE INSURANCE
COMPANY
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STIPULATION BY ALL PARTIES TO REQUEST A 60-DAY CONTINUANCE OF PRE-TRIAL
DEADLINES; ORDER
Case No. 2:17-cv-01561-KJM-CKD
302916372v1 1005131

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DATED: January 31, 2019

ORTIZ LAW GROUP, P.C.

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By: /s/ Nolan Berggren
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 60-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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Good cause appearing therefor, the Court orders the existing pretrial dates and

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deadlines extended, as follows:

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1.

Designation of expert witnesses: May 7, 2019.

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2.

Designation of rebuttal expert witnesses and percipient discovery cut

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off: June 8, 2019.
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Last day for hearings on dispositive motions: August 9, 2019 at

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10:00 a.m. in Courtroom No. 3.

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DATED: February 5, 2019.

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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