Bailey v. Unum Life Insurance Company of America

Filing 19

ORDER by Judge Haywood S. Gilliam, Jr. Granting 18 Stipulation To Continue Case Management Conference and Release Deadlines. (ndrS, COURT STAFF) (Filed on 1/19/2016)

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RIMAC MARTIN, P.C.
Anna M. Martin – CSBN 154279
[e-mail]
1051 Divisadero Street
San Francisco, CA 94115
Telephone: [phone]
Facsimile: 415.561-8430

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Attorneys for Defendant
UNUM LIFE INSURANCE COMPANY
OF AMERICA
Emily A. Bolt (State Bar No. 253109)
Brian H. Kim (State Bar No. 215492)
James P. Keenley (State Bar No. 253106)
BOLT KEENLEY KIM LLP
1010 Grayson Street, Suite Three
Berkeley, California 94710
Phone: [phone]
Fax: [phone]

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Attorneys for Plaintiff
JOLENE BAILEY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JOLENE BAILEY,

)
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Plaintiff,
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v.
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UNUM LIFE INSURANCE COMPANY OF )
AMERICA,
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Defendant.
)

Case No.: 3:15-cv-03612 HSG
JOINT STIPULATION TO CONTINUE
CASE MANAGEMENT CONFERENCE
AND RELEATED DEADLINES AND
PROPOSED ORDER
Judge: Hon. Haywood S. Gilliam, Jr.

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JOINT STIPULATION
It is hereby stipulated by and between the parties, through their attorneys of record, that
the Court continue the February 9, 2016 at 2:00 p.m. to February 19, 2016 at 2:00 p.m. and the
Case No.: 3:15-cv-03612 HSG

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JOINT CASE MANAGEMENT
STATEMENT

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January 26, 2016 joint letter filing deadline to February 9, 2016 as the parties are scheduled for

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private mediation on January 27, 2016.

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By way of background, the Court issued a November 10, 2015 minute order which stated
as follows:

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Minute Entry for proceedings held before Hon. Haywood S. Gilliam, Jr.: Case
Management Conference held on 11/10/2015. . . . . Plaintiff Attorney Brian Kim.
Defendant Attorney William Reilly. Matter is continued to February 9, 2016 at
2:00 p.m. Parties are directed to meet and confer regarding the standard of review
and scope of discovery and file a joint letter brief (5-10 pages in length) regarding
any unresolved disputes by January 26, 2016.

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The parties are scheduled to complete private mediation with Arnold Levinson on
January 27, 2016, the only date that was available for all of the parties.
Good cause exists to continue the February 9, 2016 at 2:00 p.m. Case Management
Conference and the January 26, 2016 joint letter brief filing deadline as it is possible that the case
will resolve at the mediation. If the case resolves at mediation, then there will be no need to
prepare the joint letter or appear at a Case Management Conference, allowing the parties to avoid
unnecessarily incurring attorney fees and the Court’s resources. However, if the case does not
resolve at mediation, the proposed continuance will give the parties sufficient time and
opportunity to meaningfully meet and confer and prepare a joint letter brief that will sufficiently
inform the Court on unresolved disputes regarding the standard of review and the scope of
discovery.
IT IS SO STIPULATED.
Dated: January 19, 2016

BOLT KEENLEY KIM LLP

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By: /s/ Emily Bolt
Emily Bolt
Attorneys for Plaintiff

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Case No.: 3:15-cv-03612 HSG

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JOINT CASE MANAGEMENT
STATEMENT

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Dated: January 19, 2016

RIMAC MARTIN

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By: /s/ Anna Martin
Anna Martin
Attorneys for Defendant

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ORDER

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Having reviewed the stipulation of the parties and good cause showing, the Court hereby

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GRANTS the parties’ stipulation, and ORDERS that the the Case Management Conference

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currently scheduled for February 9, 2016 at 2:00 p.m. be continued to February 23, 2016 at 2:00

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p.m., ORDERS the January 26, 2016 joint letter filing deadline be continued to February 9,

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2016.

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IT IS SO ORDERED.

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_________________________________________
Hon. Haywood S. Gilliam, Jr.
United States District Court Judge
Northern District of California

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Case No.: 3:15-cv-03612 HSG

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JOINT CASE MANAGEMENT
STATEMENT