Reid v. Accredo Health, Inc., et al

Filing 25

ORDER APPROVING STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE FROM JUNE 10, 2011 TO AUGUST 26, 2011. Signed by Judge Maxine M. Chesney on June 6, 2011. (mmclc1, COURT STAFF) (Filed on 6/6/2011)

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GEORGE J. BARRON, #53117
JONATHAN MCNEIL WONG, #112224
DONAHUE GALLAGHER WOODS LLP
Attorneys at Law
1999 Harrison Street, 25th Floor
Oakland, California 94612-3520
P.O. Box 12979
Oakland, California 94604-2979
Telephone: [phone]
Facsimile:
[phone]

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Attorneys for Plaintiff
CATHRYN REID

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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CATHRYN REID,

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CASE NO. CV 10-02332 MMC

Plaintiff,
v.
ACCREDO HEALTH GROUP, INC., a
Delaware corporation; MEDCO HEALTH
SOLUTIONS, INC., a Delaware
corporation; LINCOLN NATIONAL LIFE
INSURANCE CO., an Indiana corporation;
JEFFERSON PILOT FINANCIAL
INSURANCE COMPANY, a Nebraska
corporation; SUN LIFE ASSURANCE
COMPANY OF CANADA, a Canadian
corporation as DOE 1; and DOES 2 to 25,
inclusive,

STIPULATION, DECLARATION AND
[PROPOSED] ORDER TO CONTINUE CASE
MANAGEMENT CONFERENCE FROM
JUNE 10, 2011 TO AUGUST 26, 2011
AND ORDER THEREON

Defendants.

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Pursuant to Local Rule 6, this stipulation is made by and between plaintiff Cathryn Reid

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and defendants Accredo Health Group, Inc., Medco Health Solutions, Inc., Lincoln National Life

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Insurance Co., Jefferson Pilot Financial Insurance Company, and Sun Life Assurance Company

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of Canada, by and through their respective counsel of record, with respect to the following:

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-1STIPULATION, DECLARATION AND [PROPOSED] ORDER CONTINUING CMC

CASE NO. CV 10-02332
MMC

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WHEREAS, on August 26, 2010, the parties filed a stipulation continuing the initial case

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management conference from September 3, 2010 to October 29, 2010, which the Court approved

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on August 27, 2010;

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WHEREAS, on October 29, 2010, the Court held an initial case management conference
in this matter, which conference the Court continued to May 13, 2011;
WHEREAS, the parties filed a stipulation continuing the May 13, 2011 case management
conference to June 10, 2011, which the Court approved on April 11, 2011;

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WHEREAS, a primary reason for continuing the earlier case management conference was

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to allow sufficient time for plaintiff to make and complete the life insurance benefit claims herein.

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While significant progress has been made, those claims are not complete and more time is needed

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to do so, see Declaration of George J. Barron, attached hereto and incorporated herein by

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reference.

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WHEREAS, counsel for all parties have discussed their availability and determined that
all counsel can attend a case management conference on August 26, 2011;
NOW, THEREFORE, the parties hereby jointly request, and respectfully ask the Court to
order, as follows:

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That the case management conference be continued to August 26,

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2011, with a joint case management conference statement due on or

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before August 19, 2011.

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IT IS SO STIPULATED.
Dated: June 3, 2011

DONAHUE GALLAGHER WOODS LLP

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By: /s/ George J. Barron
George J. Barron
Attorneys for Plaintiff
Cathryn Reid

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-2STIPULATION, DECLARATION AND [PROPOSED] ORDER CONTINUING CMC

CASE NO. CV 10-02332
MMC

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Dated: June 3, 2011

BARGER & WOLEN LLP

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By: /s/ Jennifer N. Lee
Martin E. Rosen
Jennifer N. Lee

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Attorneys for Defendants
Lincoln National Life Insurance Co. and
Jefferson Pilot Financial Insurance Company

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Dated: June 3, 2011

MORGAN, LEWIS & BOCKIUS LLP

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By: /s/ Nicole A. Diller
Nicole A. Diller
Angel T. Lin

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Attorneys for Defendants
Accredo Health, Inc. and
Medco Health Solutions, Inc.

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Dated: June 3, 2011

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OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

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By: /s/ Christopher M. Ahearn
Mark Schmidtke
Christopher M. Ahearn

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Attorneys for Defendants
Sun Life Assurance Company Of Canada

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ATTESTATION

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Pursuant to General Order 45(X), I attest that concurrence in the filing of this document
has been obtained from each of the other signatories.

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Dated: June 3, 2011

DONAHUE GALLAGHER WOODS LLP

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By: /s/ George J. Barron
George J. Barron

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-3STIPULATION, DECLARATION AND [PROPOSED] ORDER CONTINUING CMC

CASE NO. CV 10-02332
MMC

DECLARATION OF GEORGE J. BARRON

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1. I am a partner at the law firm of Donahue Gallagher Woods LLP (“Donahue”),

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attorneys of record for plaintiff Cathryn Reid. I am licensed to practice law in the State of

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California and have been admitted to practice in the Northern District of California. I have direct

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and personal knowledge of the facts set forth in this declaration and, if called and sworn as a

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witness, I would competently testify to these facts.

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2. A primary reason for continuing the earlier case management conference herein was to

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allow sufficient time for plaintiff to make and complete the life insurance benefit claims herein.

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While significant progress has been made, those claims are not complete and more time is needed

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to do so.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and accurate.
Executed this 3rd day of June, 2011, at Oakland, California.
/s/ George J. Barron
George J. Barron

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-4STIPULATION, DECLARATION AND [PROPOSED] ORDER CONTINUING CMC

CASE NO. CV 10-02332
MMC

[PROPOSED] ORDER

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Pursuant to stipulation, the Court hereby ORDERS as follows:

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1. The case management conference is continued from June 10, 2011 to August 26,
2011; and

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2. The joint case management conference statement is due on or before August 19, 2011.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated:

June 6, 2011
The Honorable Maxine M. Chesney
United States District Court Judge

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-5STIPULATION, DECLARATION AND [PROPOSED] ORDER CONTINUING CMC

CASE NO. CV 10-02332
MMC