Miranda v. First Reliance Standard Life Insurance Company et al

Filing 50

Modified ORDER Granting 49 Stipulation to Continue 4/12/11 hearing. The hearing on 37 Defendants' Motion for Protective order is continued to May 4, 2011, at 1:00 p.m., and will be consolidated with the hearing on 46 Plaintiff's Motio n to Compel. The hearing will be conducted telephonically. The 47 briefing schedule on Plaintiff's Motion to Compel remains in place. Motion Hearing set for 5/4/2011 at 01:00 PM in Courtroom, 2nd Floor, Eureka before Magistrate Judge Nandor J. Vadas. Signed by Judge Nandor J. Vadas on April 11, 2011. (njvlc2, COURT STAFF) (Filed on 4/11/2011)

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ALAN E. KASSAN (SBN: 113864)
E-mail:[e-mail]
BRENT DORIAN BREHM (SBN: 248983)
E-mail:[e-mail]
KANTOR & KANTOR, LLP
19839 Nordhoff Street
Northridge, California 91324
Telephone [phone]
Facsimile [phone]
Attorneys for Plaintiff,
ROSE MIRANDA

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ADRIENNE C. PUBLICOVER (SBN 161432)
Email: [e-mail]
DENNIS J. RHODES (SBN 168417)
Email: [e-mail]
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
525 Market Street, 17th Floor
San Francisco, California 94105
Tel: [phone]
Fax: [phone]
Attorneys for Defendants
FIRST RELIANCE STANDARD INSURANCE
LIFE INSURANCE COMPANY,
RELIANCE STANDARD LIFE INSURANCE COMPANY,
and OLYMPUS AMERICA, INC. LONG TERM DISABILITY PLAN

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ROSE MIRANDA,

)
)
Plaintiff,
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)
v.
)
)
FIRST RELIANCE STANDARD INSURANCE )
LIFE INSURANCE COMPANY, RELIANCE )
STANDARD LIFE INSURANCE COMPANY, )
AND OLYMPUS AMERICA, INC. LONG
)
TERM DISABILITY PLAN,
)
)
Defendants,
)
)

Case No.:

CV09-04452 RS

STIPULATION OF THE PARTIES FOR
AN ORDER TO CONTINUE THE
HEARING DATE ON DEFENDANTS’
MOTION FOR PROTECTIVE ORDER

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STIPULATION OF THE PARTIES FOR AN ORDER TO CONTINUE THE HEARING DATE ON
DEFENDANTS’ MOTION FOR PROTECTIVE ORDER
USDC NDCA Case #CV09-04452 RS

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Defendants FIRST RELIANCE STANDARD LIFE INSURANCE COMPANY,

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RELIANCE STANDARD LIFE INSURANCE COMPANY, AND OLYMPUS AMERICA,

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INC. LONG TERM DISABILITY PLAN ("Defendants") and plaintiff Rose Miranda ("Plaintiff")

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(collectively Defendants and Plaintiff referred to as "the Parties"), by and through their counsel

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of record hereby submit this stipulation for an order to continue the hearing date on Defendants’

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Motion for Protective Order to May 4, 2011. Good cause for this continuance exists because:

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Defendants’ Motion for Protective Order is currently set for hearing on April 12, 2011.

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The issues and authorities relevant to Defendants’ Motion for Protective Order substantially

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overlap with the issues and authorities relevant to Plaintiff’s Motion to Compel. To promote the

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efficient use of the Court’s and the Parties’ time, the Parties request to have argument on both

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Defendants’ and Plaintiff’s discovery motions heard at the same time.

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Consistent with the Courts reminder to schedule civil matters with Judge Vadas’

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courtroom deputy, Gloria Masterson, the Parties have been in contact with Ms. Masterson. At

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the direction of Ms. Masterson, the Parties have conferred and prepared the instant stipulation.

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The Parties request that a telephonic hearing on both Defendants’ and Plaintiff’s discovery

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motions to be held on May 4, 2011, at 1:00 p.m.

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In connection with the continuance requested herein, and by separate stipulation, the

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Parties also sought an order from the Honorable Richard Seeborg for another 60 day continuance

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of the Discovery Cutoff, Motion Cutoff, and Trial Dates, so that both Defendants’ and Plaintiff’s

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Motions can be heard, ruled upon, and discovery can be completed, if at all, in accordance with

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the rulings of this Court.

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STIPULATION OF THE PARTIES FOR AN ORDER TO CONTINUE THE HEARING DATE ON
DEFENDANTS’ MOTION FOR PROTECTIVE ORDER
USDC NDCA Case #CV09-04452 RS

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For the reasons stated herein, the Parties respectfully request that the hearing on

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Defendants’ Motion for Protective Order be continued to May 4, 2011, and that at the same time

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a hearing on Plaintiff’s Motion to Compel take place.

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IT IS SO STIPULATED.

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Dated: April 8, 2011

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KANTOR & KANTOR, LLP

By:

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/s/ Brent Dorian Brehm
BRENT DORIAN BREHM
Attorneys for Plaintiff
ROSE MIRANDA

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Dated: April 8, 2011

WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP

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By:

/s/ Dennis J. Rhodes
ADRIENNE C. PUBLICOVER
DENNIS J. RHODES
Attorneys for Defendants
FIRST RELIANCE STANDARD LIFE INSURANCE
COMPANY, RELIANCE STANDARD LIFE INSURANCE
COMPANY, and OLYMPUS AMERICA, INC. LONG
TERM DISABILITY PLAN

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STIPULATION OF THE PARTIES FOR AN ORDER TO CONTINUE THE HEARING DATE ON
DEFENDANTS’ MOTION FOR PROTECTIVE ORDER
USDC NDCA Case #CV09-04452 RS

[MODIFIED] ORDER

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Pursuant to the stipulation of the Parties and for good cause appearing, the hearing on

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Defendants’ Motion for Protective order is continued to May 4, 2011, at 1:00 p.m., and will be

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consolidated with the hearing on Plaintiff’s Motion to Compel. The hearings will be conducted

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telephonically. The Court’s briefing schedule on Plaintiff’s Motion to Compel (Doc. No. 47)

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remains in place.

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IT IS SO ORDERED.

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Date: April 11, 2011

By:
HONORABLE NANDOR J. VADAS
UNITED STATES MAGISTRATE JUDGE

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STIPULATION OF THE PARTIES FOR AN ORDER TO CONTINUE THE HEARING DATE ON
DEFENDANTS’ MOTION FOR PROTECTIVE ORDER
USDC NDCA Case #CV09-04452 RS