Washburn v. Prudential Insurance Company of America

Filing 14

ORDER, Motions terminated: 11 STIPULATION WITH PROPOSED ORDER Regarding Filing Of Amended Complaint And Schedule For Filing Responsive Pleading filed by Prudential Insurance Company of America. Motion Hearing set for 11/20/2015 09:00 AM in Courtroom 10, 19th Floor, San Francisco before Hon. Susan Illston.. Signed by Judge Susan Illston on 9/9/15. (tfS, COURT STAFF) (Filed on 9/10/2015)

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LAURA LEIGH GEIST (Bar No. 180826)
[e-mail]
KELLY D. FAIR (Bar No. 245408)
[e-mail]
DENTONS US LLP
525 Market Street, 26th Floor
San Francisco, California 94105-2708
Telephone:
[phone]
Facsimile:
[phone]
Attorneys for Defendant
The Prudential Insurance Company of America
UNITED STATES DISTRICT COURT

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DENTONS US LLP
525 MARKET STREET , 26TH FLOOR
SAN FRANCISCO , CALIFORNIA 94105-2708
[phone]

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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GINA MARIE WASHBURN, individually and
on behalf of all others similarly situated,
Plaintiff,

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v.

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THE PRUDENTIAL INSURANCE
COMPANY OF AMERICA, a New Jersey
corporation, and DOES 1-10, inclusive,

Case No. 3:15-cv-04009 SI
STIPULATION AND [PROPOSED]
ORDER REGARDING FILING OF
AMENDED COMPLAINT AND
SCHEDULE FOR FILING
RESPONSIVE PLEADING
[Fed. R. of Civ. P. 15(a)(2); L.R. 6-1]

Defendants.

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Pursuant to Federal Rule of Civil Procedure 15(a)(2), Plaintiff GINA MARIE

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WASHBURN (“Plaintiff”) and Defendant THE PRUDENTIAL INSURANCE COMPANY OF

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AMERICA (“Defendant”) (collectively, the “Parties”) through their respective attorneys of record

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hereby enter this stipulation for the filing of an amended complaint and a schedule for response to

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that pleading:

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WHEREAS, Plaintiff filed her Complaint on July 30, 2015 in the Superior Court of
California, Contra Costa County;

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WHEREAS, Defendant removed the above-entitled action to this Court on September 2,
2015;

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Case No. 3:15-cv-04009 SI

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STIPULATION AND [PROPOSED] ORDER
REGARDING FILING OF AMENDED COMPLAINT
AND SCHEDULE FOR FILING RESPONSIVE
PLEADING

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WHEREAS, Defendant’s initial responsive pleading is due on September 9, 2015;

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WHEREAS, the Parties agreed that Plaintiff would amend her Complaint by

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supplementing and/or clarifying the allegations stated therein by September 9, 2015;

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DENTONS US LLP
525 MARKET STREET , 26TH FLOOR
SAN FRANCISCO , CALIFORNIA 94105-2708
[phone]

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WHEREAS, the Parties agreed that Defendant would respond to Plaintiff’s Amended
Complaint with a Motion to Dismiss on or before October 9, 2015;
WHEREAS, the Parties further agreed on a modified briefing schedule and to hold the
hearing on the Motion to Dismiss on November 20, 2015;
WHEREAS, the brief extension of time set forth herein will not impact any deadlines
already set by the Court in this action;
THEREFORE AND PURSUANT TO STIPULATION, the Parties through their
undersigned counsel and subject to approval by the Court, hereby request as follows:

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Plaintiff will file her Amended Complaint no later than September 9, 2015;

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Defendant’s Motion to Dismiss is due no later than October 9, 2015;

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Plaintiff’s opposition is due no later than October 30, 2015;

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Defendant’s reply is due no later than November 6, 2015; and

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Hearing on Defendant’s Motion to Dismiss shall be set for November 20, 2015.

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Dated: September 8, 2015

DENTONS US LLP

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By:

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/s/Laura Geist
Laura Leigh Geist
Kelly D. Fair

Attorneys for Defendant
The Prudential Insurance Company of America

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Dated: September 8, 2015

BRAMSON, PLUTZIK, MAHLER &
BIRKHAEUSER, LLP

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By:

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/s/Robert M. Bramson
Robert M. Bramson

Attorneys for Plaintiff
Gina Marie Washburn

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Case No. 3:15-cv-04009 SI

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STIPULATION AND [PROPOSED] ORDER
REGARDING FILING OF AMENDED COMPLAINT
AND SCHEDULE FOR FILING RESPONSIVE
PLEADING

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Attestation Pursuant to Civil L.R. 5-1(i)
Pursuant to Civil Local Rule 5-1(i), I, Laura L. Geist, hereby attest that I have obtained
concurrence in the filing of this document from the other signatory to this document. I hereby
declare under penalty of perjury that the foregoing is true and correct.
Dated: September 8, 2015

By:

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DENTONS US LLP
525 MARKET STREET , 26TH FLOOR
SAN FRANCISCO , CALIFORNIA 94105-2708
[phone]

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/s/Laura Geist
Laura Leigh Geist

[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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9/9/15
Date:_____________________

__________________________
Hon. Susan Illston
UNITED STATES DISTRICT
JUDGE

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Case No. 3:15-cv-04009 SI

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STIPULATION AND [PROPOSED] ORDER
REGARDING FILING OF AMENDED COMPLAINT
AND SCHEDULE FOR FILING RESPONSIVE
PLEADING