Lee v. Stonebridge Life Insurance Company

Filing 46

STIPULATION AND ORDER TO CONTINUE SETTLEMENT CONFERENCE DATE. Settlement Conference previously set for 2/14/12 at 9:30 AM has been re-set for 6/6/2012 at 09:30 AM in Courtroom G, 15th Floor, San Francisco. Signed by Judge Joseph C. Spero on 2/6/12. (klhS, COURT STAFF) (Filed on 2/7/2012)

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Dan Marmalefsky (SBN 95477) 1 DMarmalefsky@mofo.com 2 Tiffany Cheung (SBN 211497) 3 4 5 6 7 TCheung@mofo.com MORRISON & FOERSTER LLP 555 West Fifth Street Los Angeles, California 90013-1024 Telephone: 213.892.5200 Facsimile: 213.892.5454 Attorneys for Defendant STONEBRIDGE LIFE INSURANCE COMPANY Sean Reis (SBN 184044) 8 sreis@edelson.com Edelson McGuire, LLP 30021 Tomas Street, Suite 300 10 Rancho Santa Margarita, California 92688 Tel: 949.459.2124 11 Fax: 949.459.2123 Attorney for Plaintiff 12 JESSICA LEE 9 13 Stuart D. Kirchick (SBN 144145) sdkirchick@aol.com 14 Law Offices of Stuart D. Kirchick 1143 Story Road, Suite 210 15 San Jose, CA 95122 Tel: 408-291-0123 16 Fax: 408-291-0418 Attorney for Defendant 17 TRIFECTA MARKETING GROUP, LLC 18 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA 19 20 JESSICA LEE, individually and on behalf of a 21 class of similarly situated individuals, Plaintiff, 22 23 Case No. CV 11-0043-RS STIPULATION TO RESET SETTLEMENT CONFERENCE DATE v. 24 STONEBRIDGE LIFE INSURANCE COMPANY, a Vermont corporation, and 25 TRIFECTA MARKETING GROUP, LLC, a Florida limited liability company, Judge: Hon. Richard Seeborg Magistrate: Hon. Joseph C. Spero 26 Defendants. 27 28 STIPULATION CV-11-00043-RS 1 Pursuant to Local Rule 6-2, Plaintiff Jessica Lee, Defendant Stonebridge Life Insurance 2 Company (“Stonebridge”), and Defendant Trifecta Marketing Group, LLC (“Trifecta”) (collectively 3 referred to herein as the “Parties”), by and through their respective counsel of record, hereby 4 stipulate to move the date currently set for the settlement conference in this case as set forth below: 5 WHEREAS, Plaintiff filed the Complaint in this case on January 4, 2011 (Dkt. 1.); 6 WHEREAS, the Plaintiff and Stonebridge agreed to participate in, and the Court ordered, a 7 settlement conference in front of Hon. Joseph C. Spero (Dkt. 25.); 8 WHEREAS, the Plaintiff and Stonebridge thereafter concluded that the settlement 9 conference would not be productive without completing certain discovery and the inclusion of then 10 third-party Trifecta; 11 WHEREAS, on July 28, 2011, Plaintiff filed her First Amended Class Action Complaint 12 naming Trifecta as an additional Defendant (Dkt. 34.); 13 WHEREAS, on September 26, 2011, Stonebridge filed its Answer to the Amended 14 Complaint (Dkt. 40); 15 WHEREAS, on December 12, 2011, Trifecta filed its Answer to the Amended Complaint 16 (Dkt. 44) 17 WHEREAS, this is the Parties’ first request to continue the date of the settlement conference 18 since Trifecta’s appearance in this case (Plaintiff and Stonebridge’s fourth request since the 19 inception of the case and the first request from Trifecta), (Dkts. 29, 36, & 41.); 20 WHEREAS, counsel for the Parties have actively discussed their current positions about 21 settlement and have determined that proceeding with the settlement conference as scheduled on 22 February 14, 2012, would not be an efficient use of the Parties’ or the Court’s resources given their 23 respective views regarding settlement; 24 WHEREAS, the Parties believe that a settlement conference or other ADR method may be 25 more productive if the Parties continue with discovery; 26 WHEREAS, the stipulated continuance of the settlement conference will not alter the date of 27 any other deadlines in the schedule for the case; and 28 -1STIPULATION CV-11-00043-RS 1 WHEREAS, the Parties have informed the Court via telephone of their request to reset the 2 date of the settlement conference, and the Court has indicated that June 6, 2012 is an available date. 3 Pursuant to L.R. 6-2, IT IS HEREBY STIPULATED AND AGREED by the Parties, through 4 their counsel, that, with the Court’s agreement, the settlement conference be reset from February 14, 5 2012 to June 6, 2012. 6 Confidential settlement conference statements shall be due by May 23, 2012 - JCS 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -2STIPULATION CV-11-00043-RS 1 2 3 IT IS SO STIPULATED, THROUGH COUNSEL OF RECORD. Dated: February 3, 2012 EDELSON MCGUIRE, LLC 4 5 By 6 /s/ Ryan D. Andrews RYAN D. ANDREWS Attorney for Plaintiff JESSICA LEE 7 8 Dated: February 3, 2012 MORRISON & FOERSTER, LLP 9 10 By 11 12 13 14 /s/ Tiffany Cheung TIFFANY CHEUNG Attorney for Defendant STONEBRIDGE LIFE INSURANCE COMPANY Dated: February 3, 2012 LAW OFFICES OF STUART D. KIRCHICK 15 16 By 17 18 /s/ Stuart D. Kirchick STUART D. KIRCHICK Attorney for Defendant TRIFECTA MARKETING GROUP, LLC 19 PURSUANT TO STIPULATION, IT IS SO ORDERED. UNIT ED S ISTRIC ES D TC AT T RT U O 21 DATED: __________, 2012 Feb. 6 22 24 R NIA D RDERE _____________________________________ IS SO O FIED IT JOSEPH C. SPERO ODI AS M 23 NO UNITED STATES sMAGISTRATE JUDGE pero eph C. S ER H 26 27 FO Judge Jo LI RT 25 A 20 N F D IS T IC T O R C 28 -3STIPULATION CV-11-00043-RS

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