Dao v. Liberty Life Assurance Company of Boston

Filing 160

ORDER, Motions terminated: 159 STIPULATION WITH PROPOSED ORDER to Extend Deadlines filed by Hong-Ngoc T Dao. Jury Selection set for 8/15/2016 08:30 AM in Courtroom 1, 17th Floor, San Francisco before Hon. Susan Illston. Jury Trial set for 8/15/2016 08:30 AM in Courtroom 1, 17th Floor, San Francisco before Hon. Susan Illston. Pretrial Conference set for 8/2/2016 03:30 PM in Courtroom 1, 17th Floor, San Francisco before Hon. Susan Illston.. Signed by Judge Susan Illston on 3/30/16. (tfS, COURT STAFF) (Filed on 3/30/2016)

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PAMELA E. COGAN (SBN 105089)
STACY M. TUCKER (SBN 218942)
ROPERS, MAJESKI, KOHN & BENTLEY
1001 Marshall Street, Suite 300
Redwood City, CA 94063-2052
Telephone:
[phone]
Facsimile:
[phone]
E-Mail: [e-mail]
[e-mail]
Attorneys for Defendants
LIBERTY LIFE ASSURANCE COMPANY OF BOSTON

A Professional Corporation
Redwood City

Ropers Majeski Kohn & Bentley

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UNITED STATES DISTRICT COURT FOR
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THE NORTHERN DISTRICT OF CALIFORNIA
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HONG NGOC T. DAO,
Plaintiff,
v.
LIBERTY LIFE ASSURANCE
COMPANY OF BOSTON, a
Massachusetts corporation, and DOES 1 to
50, inclusive,

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CASE NO. 4:14-cv-04749 SI
STIPULATED REQUEST TO EXTEND
DEADLINES IN THIS ACTION OTHER
THAN THE TRIAL DATE

Defendants

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WHEREAS, the parties are interested in exploring settlement options for this litigation;
WHEREAS, the parties requested referral to a magistrate judge for settlement conference
pursuant to ADR L.R. 7-1, and were assigned to Magistrate Judge Donna Ryu;
WHEREAS, due to the schedules of the parties and Judge Ryu, the first available
settlement conference date is May 9, 2016;
WHEREAS, the parties hope to resolve this matter prior to filing summary judgment
motions and therefore seek to move the April 29, 2016 dispositive motion deadline to after the
settlement conference date;
WHEREAS, the parties have recently taken physician depositions relevant to the case and
have not yet received the transcripts of those depositions, which need to be reviewed by expert
witnesses in this action;
4814-4373-5342.1

STIPULATION TO EXTEND DEADLINES
CASE NO. 4:14-CV-04749 SI

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WHEREAS, the parties therefore also seek to move out the expert witness deadlines to
permit the deposition transcripts to be used by the witnesses;
WHEREAS. Plaintiff’s counsel will be out of the country on the scheduled date of the

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pretrial conference, July 19, 2016 and the parties therefore ask the Court to continue that

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conference;

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A Professional Corporation
Redwood City

Ropers Majeski Kohn & Bentley

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WHEREAS, the parties have twice stipulated to move the trial date in this action;
however this stipulation does not seek to reschedule the August 15, 2016 trial date;

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IT IS HEREBY STIPULATED between the parties, by and through their respective
counsel of record, that the parties respectfully ask this Court adopt the following schedule:

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Current Date

Requested New Date

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Expert Disclosures

March 30, 2016

April 29, 2016

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Expert rebuttal reports due

April 15, 2016

May 13, 2016

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Expert discovery cutoff

April 29, 2016

May 27, 2016

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Dispositive motion filing

April 29, 2016

May 27, 2016

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cutoff

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Pretrial Conference

July 19, 2016

August 1, 2016

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Trial Date

August 15, 2016

August 15, 2016

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IT IS SO STIPULATED.

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The filer of this document attests that concurrence in this filing has been obtained from all

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signatories.
Dated: March 25, 2016

BEYERS COSTIN SIMON

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By: /s/ Suzanne K. Babb
SUZANNE BABB
Attorneys for Plaintiff
HONG NGOC T. DAO

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4814-4373-5342.1

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STIPULATION TO EXTEND DEADLINES
CASE NO 4:14-CV-04749 SI

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Dated: March25, 2016

ROPERS, MAJESKI, KOHN & BENTLEY

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By: /s/ Stacy M. Tucker
PAMELA E. COGAN
STACY M. TUCKER
Attorneys for Defendant,
LIBERTY LIFE ASSURANCE
COMPANY OF BOSTON

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A Professional Corporation
Redwood City

Ropers Majeski Kohn & Bentley

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IT IS SO ORDERED.

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Dated: March ___, 2016

By:

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HON. SUSAN ILLSTON

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4814-4373-5342.1

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STIPULATION TO EXTEND DEADLINES
CASE NO 4:14-CV-04749 SI