Ramos v. United of Omaha Life Insurance Company

Filing 51

STIPULATION AND ORDER re 50 STIPULATION WITH PROPOSED ORDER Joint Stipulation and [Proposed] Order re Continuance of Case Management Conference filed by Anthony Ramos. Further Case Management Conference set for 8/21/2013 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on June 28, 2013. (wsn, COURT STAFF) (Filed on 6/28/2013)

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Terrence J. Coleman (State Bar No. 172183)
Brian H. Kim
(State Bar No. 215492)
PILLSBURY & LEVINSON, LLP
The Transamerica Pyramid
600 Montgomery St., 31st Floor
San Francisco, California 94111
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Plaintiff,
ANTHONY RAMOS

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ANTHONY RAMOS,
Plaintiff,

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vs.
UNITED OF OMAHA LIFE INSURANCE
COMPANY,

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Defendants.

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Case No. C 12-3761 JST
JOINT STIPULATION AND [PROPOSED]
ORDER RE CONTINUANCE OF CASE
MANAGEMENT CONFERENCE

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JOINT STIPULATION

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Pursuant to Local Rule 6-2, Plaintiff Anthony Ramos and Defendant United of Omaha Life
Insurance Company hereby stipulate and agree as follows:
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On June 6, 2013, the parties argued their cross-motions for judgment under Rule 52 of

the Federal Rules of Civil Procedure before the Court.
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On June 25, 2013, the Court on its motion continued the June 26, 2013 Case

Management Conference to July 31, 2013.
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From July 26, 2013 until August 9, 2013, Plaintiff’s counsel will be in the East Coast on

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a prepaid and previously reserved vacation and will therefore be unavailable for the currently

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rescheduled July 31, 2013 Case Management Conference.

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-1JOINT STIPULATION AND [PROPOSED] ORDER RE CONTINUANCE OF CASE MANAGEMENT
CONFERENCE

Case No. C 12-3761 JST

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4.

On June 26, 2013, Plaintiff’s counsel contacted Defendant’s counsel via telephone and

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informed him of Plaintiff counsel’s unavailability from July 26, 2013 until August 9, 2013 and

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specifically for the July 31, 2013 Case Management Conference. Defendant’s counsel stated that he

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will be unavailable on August 14, 2013 due to a prepaid and previously reserved vacation, but would

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be available on August 21, 2013 for a rescheduled Case Management Conference.

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Good cause exists to continue the July 31, 2013 Case Management Conference, because

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Plaintiff’s counsel will be in the East Coast on a prepaid and previously reserved vacation during that

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date. Plaintiff’s counsel has met and conferred with Defendant’s counsel and the parties have jointly

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determined that the parties would be mutually available to attend a rescheduled Case Management

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Conference on August 21, 2013.

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WHEREFORE, the parties respectfully request that the Court continue the Case

Management Conference currently scheduled for July 31, 2013 to August 21, 2013.

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IT IS SO STIPULATED.
Dated: June 27, 2013

PILLSBURY & LEVINSON, LLP

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By: /s/ Brian H. Kim
Terrence J. Coleman
Brian H. Kim
Attorneys for Plaintiff,
ANTHONY RAMOS

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Dated: June 27, 2013

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BARGER & WOLEN LLP

By: /s/ J. Russell Stedman
J. Russell Stedman
Brendan V. Mullan
Attorneys for Defendant,
UNITED OF OMAHA LIFE INSURANCE
COMPANY

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-2JOINT STIPULATION AND [PROPOSED] ORDER RE CONTINUANCE OF CASE MANAGEMENT
CONFERENCE

Case No. C 12-3761 JST

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[PROPOSED] ORDER

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Pursuant to the parties’ stipulation above, and with good cause appearing therefore,

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IT IS HEREBY ORDERED that the Case Management Conference currently scheduled for July 31,

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2013 shall be continued to August 21, 2013 at 2:00 p.m.

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IT IS SO ORDERED.

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DATED: June 28, 2013

_____________________________
HON. JON S. TIGAR
UNITED STATES DISTRICT COURT

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-3JOINT STIPULATION AND [PROPOSED] ORDER RE CONTINUANCE OF CASE MANAGEMENT
CONFERENCE

Case No. C 12-3761 JST