Aviation West Charters, LLC et al v. Connecticut General Life Insurance Company

Filing 15

ORDER RE JOINT STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND EXTEND DEADLINE TO RESPOND TO COMPLAINT by Hon. William Alsup granting 14 Stipulation.(whalc1, COURT STAFF) (Filed on 3/10/2016)

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JORDAN S. ALTURA (SBN: 209431)
TINO X. DO (SBN: 221346)
GORDON & REES LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant
CONNECTICUT GENERAL LIFE INSURANCE COMPANY

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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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Kirk J. Wolden, SBN 138902
CARTER WOLDEN CURTIS, LLP
1111 Exposition Blvd., Suite 602
Sacramento, CA 95815
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Eamon P. Kelly (Pro Hac Vice Admission to be sought)
Nathan A. Shev (Pro Hac Vice Admission to be sought)
SPERLING & SLATER, P.C.
55 West Monroe Street, Suite 3200
Chicago, IL 60603
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

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Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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AVIATION WEST CHARTERS, LLC D/B/A
ANGEL MEDFLIGHT, et al.

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Plaintiffs,
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vs.
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CONNECTICUT GENERAL LIFE INSURANCE
COMPANY

CASE NO. 4:16-cv-00035-WHA
Order Re:

JOINT STIPULATION TO
CONTINUE INITIAL CASE
MANAGEMENT CONFERENCE
AND EXTEND DEADLINE TO
RESPOND TO COMPLAINT
(CIVIL L.R. 16(e) AND 6-1(a))
Complaint Filed: January 11, 2016

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Defendant.

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Order re:

-1Case No. 4:16-cv-00035-WHA
JOINT STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE
AND EXTEND DEADLINE TO RESPOND TO COMPLAINT

Case 3:16-cv-00035-WHA Document 14 Filed 03/02/16 Page 2 of 5

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TO THE HONORABLE COURT:

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The parties hereto, Plaintiffs AVIATION WEST CHARTERS, LLC d/b/a ANGEL

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MEDFLIGHT and ERIN GAAL (collectively “Plaintiffs”) and Defendant CONNECTICUT

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GENERAL LIFE INSURANCE COMPANY (“CIGNA”), by and through their respective

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counsel of record, hereby stipulate as follows:

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WHEREAS, Plaintiffs filed their Complaint on January 5, 2016, and served CIGNA with
the Summons and Complaint on January 8, 2016.
WHEREAS, following joint stipulations, CIGNA’s current deadline to file a response to
the Complaint is March 2, 2016.
WHEREAS, the Parties have agreed to conduct an early mediation on March 31, 2016

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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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with Judge Edward Infante (Ret.) to attempt to resolve this case and potentially resolve other,

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related claim disputes in their entirety.

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WHEREAS, given the complexities of this case and the other disputes, the Parties agree

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that sufficient time should be allowed post-mediation to permit resolution efforts to continue and,

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if the Parties are unable to resolve their disputes, to allow CIGNA adequate time to prepare its

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response to the Complaint.

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WHEREAS, the Plaintiffs have agreed to extend CIGNA’s deadline to file a response to

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the Complaint to April 22, 2016, provided this date will not interfere with any deadline

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previously set by the Court.

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WHEREAS, this Court scheduled the Initial Case Management Conference on
Reassignment for April 14, 2016.

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WHEREAS, the Parties request the Court to continue the Initial Case Management

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Conference to April 28, 2016 to complete early resolution efforts and, if these efforts are

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unsuccessful, to permit CIGNA to file a responsive pleading in advance of the Case Management

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Conference.

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IT IS HEREBY STIPULATED by and between Plaintiffs and CIGNA through their

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respective counsel of record that the deadline for CIGNA to file a responsive pleading is

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Order re:
-2Case No. 4:16-cv-00035-WHA
JOINT STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE
AND EXTEND DEADLINE TO RESPOND TO COMPLAINT

Case 3:16-cv-00035-WHA Document 14 Filed 03/02/16 Page 3 of 5

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extended up to April 22, 2016, and that the Court continue the Initial Case Management

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Conference to April 28, 2016.

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IT IS SO STIPULATED

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Dated: March 2, 2016

CARTER WOLDEN CURTIS, LLP

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By

/s/ Kirk J. Wolden
Kirk J. Wolden
Attorneys for Plaintiffs
AVIATION WEST CHARTERS, LLC d/b/a
ANGEL MEDFLIGHT and ERIN GAAL

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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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Dated: March 2, 2016

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GORDON & REES LLP
By /s/ Jordan S. Altura
Jordan S. Altura
Tino X. Do
Attorneys for Defendant
CONNECTICUT GENERAL LIFE INSURANCE
COMPANY

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Order re:

-3Case No. 4:16-cv-00035-WHA
JOINT STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE
AND EXTEND DEADLINE TO RESPOND TO COMPLAINT

Case 3:16-cv-00035-WHA Document 14 Filed 03/02/16 Page 4 of 5

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ATTESTATION OF E-FILED SIGNATURE
I, Jordan S. Altura, am the ECF user whose ID and password are being used to file this
Joint Stipulation to Continue Initial Case Management Conference and Extend Deadline to
Respond to Complaint. In compliance with Local Rule 5-1(i), I hereby attest that Kirk J.
Wolden, counsel for Plaintiffs, has concurred in this filing.

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Dated: March 2, 2016

/s/ Jordan S. Altura
Jordan S. Altura

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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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1114817/27000634v.1

Order re:

-4Case No. 4:16-cv-00035-WHA
JOINT STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE
AND EXTEND DEADLINE TO RESPOND TO COMPLAINT

Case 3:16-cv-00035-WHA Document 14 Filed 03/02/16 Page 5 of 5

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PROPOSED ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED that the Initial Case

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Management Conference is continued to April 28, 2016 at 11:00 a.m. Not less than seven days

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prior, counsel shall submit a joint case management conference statement not to exceed ten

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pages.

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IT IS FURTHER ORDERED that Defendant Connecticut General Life Insurance

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Company file its response to Plaintiffs’ Complaint by April 22, 2016 in the event this case is not

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resolved at mediation.

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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111

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March 10, 2016.
Dated: ________________

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__________________________
Hon. William Alsup
United States District Judge

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Order re:

-5Case No. 4:16-cv-00035-WHA
JOINT STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE
AND EXTEND DEADLINE TO RESPOND TO COMPLAINT