Hadar Meiri v. Hartford Life and Accident Insurance Company

Filing 38

STIPULATION AND ORDER re 37 STIPULATION WITH PROPOSED ORDER (Stipulation and [Proposed] Order for One-Week Continuance of Hearing for Cross-Motions for Judgment Under FRCP Rule 52 and Motion to Strike) filed by Hartford Life and Accident Insurance Company. Signed by Judge Jon S. Tigar on February 27, 2017. (wsn, COURT STAFF) (Filed on 2/27/2017)

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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]
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 AND
[PROPOSED] ORDER FOR ONEWEEK CONTINUANCE OF
HEARING FOR CROSS-MOTIONS
FOR JUDGMENT UNDER FRCP
RULE 52 AND MOTION TO
STRIKE
CURRENT DATE: March 9, 2017
CURRENT TIME: 2:00 p.m.

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PROPOSED DATE: March 16, 2017
PROPOSED TIME: 2:00 p.m.

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Complaint Filed: January 7, 2016

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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 one-week continuance of

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the hearing date on all motions set for March 9 to March 16, 2017, at 2:00 p.m.

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Good cause exists as follows:

B UR KE , W I L LIA M S &
S O RE N S E N , L L P
A T T O RNE YS A T L A W
L O S A N GE L E S

CASE NO. 3:16-CV-00103-JST
LA #4819-9283-2067 v1

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STIP & [PROPOSED] ORDER FOR ONE-WEEK
CONT OF HRG ON THE X-MOTS FOR JDMT & MTS

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Whereas counsel for Defendant Hartford, Melissa M. Cowan, learned on the
afternoon of February 22, 2017, that her nine-year-old daughter would require
surgery as soon as possible. For medical reasons, the surgery cannot be scheduled
for two weeks. The surgeon has now confirmed that surgery will proceed on
Thursday, March 9, 2017 at UCLA Medical Center in Los Angeles, California.
Whereas the parties’ cross-Motions for Judgment under FRCP Rule 52 and

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Plaintiff’s Motion to Strike are set to be heard at 2:00 p.m. on March 9, the same

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date as the surgery. Defendant’s counsel requested that Plaintiff’s counsel agree to

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a one-week continuance of the March 9 th hearing to accommodate this unexpected

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medical matter. Plaintiff’s counsel, Ms. Grey, graciously agreed.
All the briefing for the cross-Motions for Judgment (Doc. Nos. 21, 24, 29,
34, 35) and Motion to Strike (Doc. Nos. 30, 33, 36) has been completed. The
briefing on Defendant’s Motion for Administrative Relief related to Plaintiff’s
opening Motion (Doc. Nos. 25, 26) has likewise been submitted.
Whereas the parties have confirmed that the court’s calendar is still open for
hearings on March 16 (although it is closed for hearings on March 9). The parties
therefore request that the hearing date for both the Cross-Motions for Judgment and
the Motion to Strike be moved from March 9, 2017 at 2:00 p.m., to March 16, 2017
at 2:00 p.m. The parties seek only a one-week continuance of the hearing date.
Currently, March 23 is not an available date for counsel. March 30 is also closed
on the court’s calendar for further hearings.
The parties previously requested two extensions of time related to the
briefing for the cross-Motions for Judgment, with a commensurate continuance of
the hearing date. The parties first 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, and other conflicts. (Doc. Nos. 27, 28) Plaintiff’s

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responsive brief deadline was extended from November 30, 3016 to January 5,

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B UR KE , W I L LIA M S &
S O RE N S E N , L L P
A T T O RNE YS A T L A W
L O S A N GE L E S

CASE NO. 3:16-CV-00103-JST
LA #4819-9283-2067 v1

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STIP & ORDER FOR 1-WK CONT OF HRG ON XMTNS FOR JDMT & MTS METSMTSMTS

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2017; Defendant’s responsive brief was extended from December 21, 2016 to
February 2, 2017; and the Motion hearing moved from January 12 to February 16,

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2017, at 2:00 p.m. The parties requested a second extension for Defendant’s

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responsive brief and opposition to Plaintiff’s Motion to Strike due to Defendant’s

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counsel having to prepare for and participate in trial on January 30, 2017. (Doc.

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Nos. 31, 32) The court continued Defendant’s opposition to Plaintiff’s Motion to

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Strike from January 19 to February 7, 2017; Plaintiff’s reply for the Motion to

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Strike to February 16, 2017; Defendant’s responsive brief for the cross-Motion for

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Judgment from February 2 to February 16, 2017; and the hearing date for crossMotions for Judgment and the Motion to Strike from February 16 to March 9, 2017
at 2:00 p.m.
Due to this unforeseen medical matter, the parties respectfully request that
the pending motions be heard on March 16, 2017 at 2:00 p.m., rather than March 9.
IT IS SO STIPULATED.
Dated: February 27, 2017

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By:/s/ Rebecca Grey [as authorized on 2/27/17
Rebecca Grey
Attorneys for Plaintiff Hadar Meiri

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

Dated: February 27, 2017

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Burke, Williams & Sorensen, LLP
Melissa M. Cowan
By: /s/ Melissa M. Cowan
Melissa M. Cowan
Attorneys Defendant Hartford Life
and Accident Insurance Company

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B UR KE , W I L LIA M S &
S O RE N S E N , L L P
A T T O RNE YS A T L A W
L O S A N GE L E S

CASE NO. 3:16-CV-00103-JST
LA #4819-9283-2067 v1

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STIP & ORDER FOR 1-WK CONT OF HRG ON XMTNS FOR JDMT & MTS METSMTSMTS

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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DATED: February 27, 2017

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__________________________________
Honorable Jon S. Tigar
United States District Court Judge

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B UR KE , W I L LIA M S &
S O RE N S E N , L L P
A T T O RNE YS A T L A W
L O S A N GE L E S

CASE NO. 3:16-CV-00103-JST
LA #4819-9283-2067 v1

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STIP & ORDER FOR 1-WK CONT OF HRG ON XMTNS FOR JDMT & MTS METSMTSMTS