Hadar Meiri v. Hartford Life and Accident Insurance Company

Filing 32

STIPULATION AND ORDER re 31 STIPULATION WITH PROPOSED ORDER REGARDING BRIEFING SCHEDULE FOR CROSS-MOTIONS FOR JUDGMENT and REQUEST FOR CHANGE IN HEARING DATE filed by Hartford Life and Accident Insurance Company. Signed by Judge Jon S. Tigar on January 18, 2017. (wsn, COURT STAFF) (Filed on 1/18/2017)

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Rebecca Grey (SBN 194940)
E-mail: [e-mail]
Kate Rozenvasser (State Bar No. 251403)
Email: [e-mail]
THE GREY LAW FIRM, P.C.
235 Montgomery Street, Suite 1101
San Francisco, CA 94104
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff Hadar Meiri
Melissa M. Cowan, (SBN 175326)
E-mail: [e-mail]
Keiko J. Kojima (SBN 206595)
E-mail: [e-mail]
BURKE, WILLIAMS & SORENSEN, LLP
444 South Flower Street, Suite 2400
Los Angeles, CA 90071-2953
Tel: [phone]
Fax: [phone]

Attorneys for Defendant Hartford Life and Accident
Insurance Company

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

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HADAR MEIRI, an individual,

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Plaintiff,

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v.

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HARTFORD LIFE AND ACCIDENT
INSURANCE COMPANY,

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Defendant.

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Case No. 3:16-cv-00103-JST

STIPULATION FOR TWO-WEEK
CONTINUANCE FOR REMAINING
BRIEFING FOR CROSS -MOTION
FOR JUDGMENT AND HEARING
DATE; [PROPOSED] ORDER
Complaint Filed: January 7, 2016

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For the reasons set forth below, the parties respectfully request that the Court

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permit a continuance of the following briefing schedule deadline and corresponding

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change in the hearing date:

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///

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///

B URKE , W ILLIAMS &
S ORENS EN , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

LA #4852-6475-5008 v1

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CASE NO. 3:16-CV-00103-JST
STIPULATION TO CONTINUE MOTION
BRIEFING DATES

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By and through their counsel of record, Plaintiff Hadar Meiri (“Meiri”) and

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Defendant Hartford Life and Accident Insurance Company (“Hartford”), hereby

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stipulate and respectfully request that the Court permit a two-week continuance of

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the remaining briefing schedule deadlines with a corresponding change in the

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hearing date. Good cause exists as follows:

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Whereas in this ERISA case, the Court set a briefing schedule for the parties’

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respective Cross-motions for Judgment under FRCP Rule 52. (Doc. 19) Plaintiff

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Meiri filed her Motion for Judgment on October 19, 2016. Defendant Hartford

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filed its Motion for Judgment on November 9, 2016.

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Whereas the parties requested a continuance of the responsive motion

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deadlines and trial due to the medical leave and rehabilitation of Plaintiff’s counsel,

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Rebecca Grey, in late October, as well as limited availability of legal staff and

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conflicts from winter holidays. The Court set the following dates: Plaintiff’s

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responsive brief extended from November 30, 3016 to January 5, 2017;

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Defendant’s responsive brief extended from December 21, 2016 to February 2,

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2017; and the Motion hearing moved from January 12, 2017 to February 16, 2017,

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at 2:00 p.m.

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Since that time, in late November, Defendant’s counsel, Melissa M. Cowan,

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had a trial set for January 30, 2016, in the United States District Court, Northern

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District of California, in Arlene Tom v. Hartford Life and Accident Insurance

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Company, Case No. 16-cv-01067. The pre-trial conference in that case is set for

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January 18, 2017, and the district court has already confirmed trial will proceed as

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scheduled. Ms. Cowan is the only attorney handling the Meiri case, such that the

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January 30th trial will affect her ability to prepare and complete Hartford’s

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responsive brief which is due that same week. Ms. Cowan’s husband is also

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scheduled for surgery on January 25, 2017, and it cannot be moved.

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B URKE , W ILLIAMS &
S ORENS EN , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

Plaintiff filed her responsive brief on January 5, 2017, which included a
motion to strike a prior declaration filed by Defendant’s counsel. The parties met
LA #4852-6475-5008 v1

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CASE NO. 3:16-CV-00103-JST
STIPULATION TO CONTINUE MOTION
BRIEFING DATES

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and conferred and propose the following new schedule to accommodate these

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unavoidable issues.

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• Defendant’s opposition to Plaintiff’s motion to strike, currently due on
January 19, 2017, shall be extended to February 7, 2017.
• Plaintiff’s reply for the motion to strike shall be extended to February 16,
2017
• Defendant’s responsive brief for the cross-Motion for Judgment, currently
due on February 2, 2017, shall be extended to February 16, 2017.
• The parties request that the hearing date for both the cross-Motions for

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Judgment and the Motion to Strike be moved from February 16, 2017 at

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2:00 p.m., to March 9, 2017 at 2:00 p.m. The court’s website reflects that

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the Court is not available for hearings on March 2.

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IT IS SO STIPULATED

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Dated: January 13, 2017

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By: /s/ Rebecca Grey [as authorized
on 1/13/17]
Rebecca Grey
Attorneys for Plaintiff Hadar Meiri

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The Grey Law Firm, P.C.
Rebecca Grey
Kate Rozenvasser

Dated: January 13, 2017

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Burke, Williams & Sorensen, LLP
Melissa M. Cowan
Keiko J. Kojima

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By: /s/ Melissa M. Cowan
Melissa M. Cowan
Attorneys Defendant Hartford Life
and Accident Insurance Company

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B URKE , W ILLIAMS &
S ORENS EN , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

LA #4852-6475-5008 v1

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CASE NO. 3:16-CV-00103-JST
STIPULATION TO CONTINUE MOTION
BRIEFING DATES

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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DATED: January 18, 2017

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__________________________________
Honorable Jon S. Tigar
United States District Court Judge

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B URKE , W ILLIAMS &
S ORENS EN , LLP
ATTO RNEY S AT LAW
LOS A NG EL ES

LA #4852-6475-5008 v1

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CASE NO. 3:16-CV-00103-JST
STIPULATION TO CONTINUE MOTION
BRIEFING DATES