Vela v. AT&T Inc. et al

Filing 90

ORDER TO CONTINUE FILING DATES RELATED TO PARTIES' MOTIONS FOR SUMMARY JUDGMENT. The parties' deadline for re-noticing their respective motions for aummary judgment and for filing further briefing is continued from November 4, 2011 to December 5, 2011. The deadline for filing responses to further briefing is continued from November 18, 2011 to December 19, 2011. Signed by Judge Maxine M. Chesney on October 24, 2011. (mmclc2, COURT STAFF) (Filed on 10/24/2011)

1 Katherine L. Kettler (SBN 231586)
[e-mail]
2 Jennifer A. Shy (SBN 131074)
[e-mail]
3 MILLER LAW GROUP
A Professional Corporation
4 111 Sansome Street, Suite 700
San Francisco, CA 94104
5 Tel. [phone]
Fax [phone]
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Attorneys for Defendant
7 AT&T UMBRELLA BENEFIT PLAN NO. 1
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Lee S. Harris (SBN 076699)
[e-mail]
GOLDSTEIN, GELLMAN, MELBOSTAD,
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HARRIS & MCSPARRAN, LLP
1388 Sutter Street, Suite 1000
11 San Francisco, CA 94103
Tel: [phone]
12 Fax: [phone]
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13 Attorneys for Plaintiff
LOUIS J. VELA
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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LOUIS J. VELA,

Case No.: CV 08 1575 MMC

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Plaintiff,

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STIPULATION AND [PROPOSED] ORDER
TO CONTINUE FILING DATES RELATED
TO PARTIES’ MOTIONS FOR SUMMARY
JUDGMENT

AT&T UMBRELLA BENEFIT PLAN NO. 1,
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Defendant.

Complaint filed: March 21, 2008
First Am. Complaint filed: May 14, 2008
Second Am. Complaint filed: Oct. 9, 2008

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE FILING DATES RELATED TO
PARTIES’ MOTIONS FOR SUMMARY JUDGMENT
Case No.: CV 08 1575 MMC

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Plaintiff Louis Vela (“Plaintiff”) and Defendant AT&T Umbrella Benefit Plan No. 1

2 (“Defendant”) (collectively the “Parties”), by and through their respective counsel of record,
3 hereby stipulate as follows:
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The Parties previously stipulated to a briefing schedule in support of their

6 respective Motions for Summary Judgment as reflected in the Court’s Order filed on August
7 12, 2011 (Docket No. 86). Now, the Parties stipulate and respectfully request the Court to
8 further continue the Parties’ present deadline for re-noticing their respective Motions for
9 Summary Judgment and for filing Further Briefing, from November 4, 2011 to December 5,
10 2011, and continue the Parties’ present deadline for filing Responses to Further Briefing from
11 November 18, 2011 to December 19, 2011. The Parties also request that the Court allow
12 each Party up to ten (10) pages for their Responses to Further Briefing (instead of the five
13 pages currently allowed.)
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Good cause exists for the requested continuance of these filing dates, as the re-

16 opened deposition of Ms. Tonya Warner was taken on October 13, 2011, and the extension of
17 time allows a reasonable time for the completion of the transcript, as well as the 30-day
18 statutory review period set forth in the Federal Rules of Civil Procedure, Rule 30(e).
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The Parties wish to further inform that Court that they have engaged, through

21 their respective counsel, in discussion about the possibility of conducting further efforts to
22 informally resolve this dispute. In the event that the Parties agree to such further efforts, the
23 Parties may approach the Court to request a further continuance of the dates above related to
24 the filing of the Parties’ Motions for Summary Judgment.
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STIPULATION AND [PROPOSED] ORDER TO CONTINUE FILING DATES RELATED TO
PARTIES’ MOTIONS FOR SUMMARY JUDGMENT
Case No.: CV 08 1575 MMC

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IT IS SO STIPULATED.

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3 Dated: October 20, 2011

GOLDSTEIN, GELLMAN, MELBOSTAD,
HARRIS & MCSPARRAN, LLP

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By:
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/s/
Lee S. Harris
Attorneys for Plaintiff
LOUIS J. VELA

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Dated: October 20, 2011

MILLER LAW GROUP
A Professional Corporation

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By:

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/s/
Katherine L. Kettler
Attorneys for Defendant
AT&T UMBRELLA BENEFIT PLAN NO. 1

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IT IS SO ORDERED

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October 24
Dated: ______________, 2011

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_______________________________________
HONORABLE MAXINE M. CHESNEY

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4817-6513-4348, v. 2

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE FILING DATES RELATED TO
PARTIES’ MOTIONS FOR SUMMARY JUDGMENT
Case No.: CV 08 1575 MMC