Knopp v. Life Insurance Company of North America et al

Filing 58

ORDER continuing trial and pretrial conference re 57 Stipulation filed by Tamara Knopp Jury Trial set for 5/17/2010 08:30 AM in Courtroom 8, 19th Floor, San Francisco. Pretrial Conference set for 5/11/2010 02:30 PM in Courtroom 8, 19th Floor, San Francisco.. Signed by Judge Charles R. Breyer on 3/9/2010. (be, COURT STAFF) (Filed on 3/11/2010)

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Steven P. Krafchick Washington State Bar No. 13542 Pro Hac Vice KRAFCHICK LAW FIRM 100 W. Harrison, South Tower, Suite 300 Seattle, WA 98119 [phone] (Telephone) [phone] (Facsimile) [e-mail] Mr. Abraham N. Goldman California State Bar No. 102080 ABRAHAM N. GOLDMAN & ASSOCIATES, LTD P.O. Box 120 / 12896 Rices Crossing Road Oregon House, CA 95962 [phone] (Telephone) [phone] (Fax) [e-mail] Attorneys for Plaintiff TAMARA KNOPP UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION TAMARA KNOPP, Plaintiff, v. LIFE INSURANCE COMPANY OF NORTH AMERICA, and NOVARTIS VACCINES AND DIAGNOSTIC, INC. INSURANCE PLAN, Defendants. Case No. CV-09-0452 CB STIPULATION AND [PROPOSED] ORDER CONTINUING THE TRIAL AND THE PRETRIAL CONFERENCE IN THIS MATTER HON: CHARLES BREYER TRIAL DATE: MARCH 29, 2010 PRE-TRIAL: MARCH 22, 2010

STIPULATION AND PROPOSED ORDER CONTINUING THE TRIAL

KRAFCHICK LAW FIRM 100 W. Harrison St, S. Tower, #300 Seattle, WA 98119 Case No. CV-09-0452 JL

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STIPULATION AND PROPOSED ORDER CONTINUING THE TRIAL

Plaintiff TAMARA KNOPP and Defendants LIFE INSURANCE COMPANY OF NORTH AMERICA and NOVARTIS VACCINES AND DIAGNOSTIC, INC. INSURANCE PLAN (collectively "the Parties"), through their respective counsel, hereby request and stipulate to a continuance of the pretrial conference and trial in this matter, currently set for March 23, 2010, March 29, 2010, respectively, for the following reasons: This matter involves a bench trial under the Employee Retirement Income Security Act of 1974 ("ERISA"). This matter currently is set for a bench trial on March 29, 2010 with a pretrial conference set for March 22, 2010. Settlement negotiations have been on-going since February 1, 2010. Significant progress has been made toward settlement with concessions by all Parties, but the Parties have not been able to come to a complete agreement as of March 5, 2010. Negotiations continue and slightly more time will benefit the negotiations. The parties request a telephone settlement conference with the Magistrate assigned to this matter on a date as soon as reasonably possible that works for all parties and counsel. In addition, additional time is needed to complete court ordered discovery in the event this matter does not settle. Finally, the current trial date of March 29, 2010 is the start of the Passover holiday making it both highly inconvenient and prohibitive for both Steven Krafchick and Abraham Goldman, Plaintiff's counsel. Defendants' counsel, Sean Nalty, has no objection to moving the trial date in order to accommodate Plaintiff's counsel. The parties suggest any of the following dates for the new trial: May 3, May 10, May 17 or June 7. Based on the forgoing, the parties hereby stipulate that the trial in this matter can be moved to May 3, May 10, May 17, or June 7 and respectfully request that the Court continue the trial and the pre-trial conference accordingly.
KRAFCHICK LAW FIRM 100 W. Harrison St, S. Tower, #300 Seattle, WA 98119 Case No. CV-09-0452 JL

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Dated: March 8th, 2010 /s/ Steven P. Krafchick___ STEVEN P. KRAFCHICK KRAFCHICK LAW FIRM /s/ Abraham N. Goldman___ ABRAHAM N. GOLDMAN California State Bar No. 102080 ABRAHAM N. GOLDMAN & ASSOCIATES, LTD Attorneys for Plaintiff TAMARA KNOPP Dated: March 8th, 2010 /s/ Sean P. Nalty SEAN P. NALTY WILSON ELSER Attorneys for Defendant LIFE INSURANCE COMPANY OF NORTH AMERICA

STIPULATION AND PROPOSED ORDER CONTINUING THE TRIAL

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KRAFCHICK LAW FIRM 100 W. Harrison St, S. Tower, #300 Seattle, WA 98119 Case No. CV-09-0452 JL

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STIPULATION AND PROPOSED ORDER CONTINUING THE TRIAL

[PROPOSED] ORDER Pursuant to the Stipulation above, the Trial for the above captioned matter is hereby: May 17, 2010 at Continued to _____________, 8:30 a.m.. The clerk shall issue a new Order setting the Pre-Trial Conference accordingly; The pre-trial conference is continued to May 11, 2010 at 2:30 p.m. IT IS SO ORDERED.

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March 9, 2010 Dated: __________________

_________________________________ THE HONORABLE CHARLES R. BREYER RED

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KRAFCHICK LAW FIRM 100 W. Harrison St, S. Tower, #300 Seattle, WA 98119 Case No. CV-09-0452 JL

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