Lee v. Stonebridge Life Insurance Company

Filing 138

STIPULATION AND ORDER REGARDING EXTENSION OF EXPERT DISCOVERY DEADLINE. Signed by Judge Richard Seeborg on 9/26/13. (cl, COURT STAFF) (Filed on 9/26/2013)

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DAN MARMALEFSKY (CA SBN 95477)
[e-mail]
MORRISON & FOERSTER LLP
707 Wilshire Boulevard
Los Angeles, California 90017-3543
Telephone: [phone]
Facsimile: 213.892.5454
TIFFANY CHEUNG (CA SBN 211497)
[e-mail]
MORRISON & FOERSTER LLP
425 Market Street
San Francisco, California 94105-2482
Telephone: [phone]
Facsimile: 415.268.7522
Attorneys for Defendant
STONEBRIDGE LIFE INSURANCE COMPANY

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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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JESSICA LEE, individually and on behalf of a
class of similarly situated individuals,

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Plaintiff,
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v.
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STONEBRIDGE LIFE INSURANCE
COMPANY, a Vermont corporation, and
TRIFECTA MARKETING GROUP LLC, a
Florida limited liability company,

Case No.

CV 11-0043-RS

STIPULATION AND
[PROPOSED] ORDER
REGARDING EXTENSION OF
EXPERT DISCOVERY
DEADLINE
Judge:

Hon. Richard Seeborg

Action Filed:
Trial Date:

Defendants.

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STIPULATION AND [PROPOSED] ORDER RE EXTENSION OF EXPERT DISCOVERY DEADLINE
CV 11-0043-RS
sf-3335565

Jan. 4, 2011
June 23, 2014

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Defendant Stonebridge Life Insurance Company (“Stonebridge”) and Plaintiff Jessica Lee

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(collectively with Stonebridge, the “Parties,” each a “Party”), by and through their respective

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counsel of record, hereby enter into the following stipulation:

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WHEREAS, on May 28, 2013, the Court entered an order setting the deadline for
completion of all expert discovery for September 27, 2013. (ECF No. 112.)

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WHEREAS, on August 8, 2013, the Parties exchanged Rule 26(a)(2) expert reports;

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WHEREAS, on September 6, 2013, the Parties exchanged rebuttal expert reports;

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WHEREAS, the Parties have propounded written discovery requests on experts, and the

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experts have responded to such requests;
WHEREAS, as a result of scheduling conflicts, the Parties have been unable to schedule
expert depositions for mutually convenient times prior to the current September 27 deadline;
WHEREAS, the Parties have agreed to schedule the depositions of two experts on
October 3, 2013, and October 4, 2013;
WHEREAS, the Parties expect to reach agreement on the schedule for the remaining
expert depositions shortly;
WHEREAS, this case is not set for trial until June 23, 2014, and a short extension of the
deadline for completion of expert discovery should not impact other case deadlines;
THEREFORE, subject to the approval of the Court, the Parties agree and stipulate as
follows:
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The deadline for completion of expert discovery is extended from September 27,

2013 to October 25, 2013.

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STIPULATION AND [PROPOSED] ORDER RE EXTENSION OF EXPERT DISCOVERY DEADLINE
CV 11-0043-RS
sf-3335565

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IT IS SO STIPULATED.

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Dated: September 25, 2013.

MORRISON & FOERSTER LLP

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By:

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Attorneys for Defendant
STONEBRIDGE LIFE INSURANCE
COMPANY

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/s/ Tiffany Cheung
TIFFANY CHEUNG

Dated: September 25, 2013

EDELSON LLC

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By:

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/s/ Ryan D. Andrews
RYAN D. ANDREWS

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Attorneys for Plaintiff
JESSICA LEE and the class

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ATTESTATION OF FILER

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I, Tiffany Cheung, hereby attest that concurrence in the filing of this document has been
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obtained from each of the other signatories. See L.R. 5-1(i)(3).
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Dated: September 25, 2013

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By:

/s/ Tiffany Cheung
TIFFANY CHEUNG
MORRISON & FOERSTER LLP

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PURSUANT TO STIPULATION, IT IS SO ORDERED

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Dated: 9/26/13
Hon. Richard Seeborg
United States District Judge

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STIPULATION AND [PROPOSED] ORDER RE EXTENSION OF EXPERT DISCOVERY DEADLINE
CV 11-0043-RS
sf-3335565

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