Erina Llamas v. Life Insurance Company of North America
Filing
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ORDER granting 28 MOTION to Continue Briefing Schedule. Dispositive motions heard by 8/23/2017. Signed by Judge William H. Orrick on 06/07/2017. (jmdS, COURT STAFF) (Filed on 6/7/2017)
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Scott Kalkin 120791
ROBOOSTOFF & KALKIN
A Professional Law Corporation
369 Pine Street, Suite 820
San Francisco, California 94104
(415) 732-0282
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Attorney for Plaintiff Erina Llamas
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Anna M. Martin 154279
MESERVE, MUMPER & HUGHES LLP
800 Wilshire Boulevard, Suite 500
Los Angeles, California 90017-2611
(213) 620-0300
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Attorneys for Defendant
Life Insurance Company of North America
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IN THE UNITED STATES DISTRICT COURT
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FOR THE NORTHERN DISTRICT OF CALIFORNIA
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Erina Llamas,
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Plaintiff,
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v.
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Life Insurance Company of
North America,
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Defendant.
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ACTION NO.: 16-cv-3293 WHO
STIPULATION AND ORDER
ORDER TO CONTINUE BRIEFING
BRIEFING SCHEDULE FOR
CROSS-MOTIONS FOR
SUMMARY JUDGMENT
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It is hereby stipulated by and between the parties through their respective counsel that
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Plaintiff Erina Llamas and Defendant Life Insurance Company of North America may have
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additional time within which to file the administrative record and the their respective cross-
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motions for summary judgment in this matter.
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Pursuant to Local Rule 6-1(b) the parties submit this request to continue the briefing
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Stipulation to Continue Briefing Schedule
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Case No: 16-3293 WHO
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schedule in this matter for approximately thirty (30) days.
This is an ERISA long term disability case which will require the Court to review an
administrative record consisting of approximately two thousand (2000) pages.
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During the course of briefing this matter plaintiff’s counsel discovered that the
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administrative record provided to him by defense counsel may not be complete. There are
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nine hundred and ninety five (995) pages potentially at issue, but without reviewing and
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comparing each document at issue, it is difficult to be certain.
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Counsel discussed this matter on June 5, 2017, and are attempting to sort this issue
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out with an eye toward providing the Court with one set of documents to review rather than
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two. This will facilitate both counsels’ citation to the record in their respective briefs and make
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the court’s review of the same more efficient.
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Given the volume of documents involved, it will be difficult to resolve this issue prior to
the current due date for the parties’ cross-motions.
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Additionally, during the course of discussing the issues surrounding the administrative
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record, counsel reopened their settlement negotiations and both sides would like additional
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time to re-consider their respective positions.
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In light of the forgoing, good cause exists to continue the briefing schedule in this matter
for approximately thirty (30) days.
Counsel propose the following changes to the briefing schedule:
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Schedule
Current Dates
Stipulated New Dates
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Opening Brief Due
June 7, 2017
July 5, 2017
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Opposition Briefs Due
June 28, 2017
July 26, 2017
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Reply Briefs Due
July 5, 2017
August 2, 2017
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Hearing Date
July 19, 2017
August 23, 2017
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This document is being filed through the Court’s ECF system. In this regard, counsel
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for plaintiff hereby attests that: 1) the content of this document is acceptable to all persons
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Stipulation to Continue Briefing Schedule
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Case No: 16-3293 WHO
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required to sign it; 2) defendant has concurred in the filing of this document; and 3) a record
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supporting this concurrence is available for inspection or production if so ordered.
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Respectfully submitted,
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ROBOOSTOFF & KALKIN
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Dated: June 6, 2017
By:
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/s
Scott Kalkin
Attorneys for Plaintiff
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MESERVE, MUMPER & HUGHES LLP
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Dated: June 6, 2017
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By:
/s
Anna M. Martin
Attorneys for Defendant
Life Insurance Company of
North America
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[PROPOSED] ORDER
Good cause having been shown, the Court hereby continues the briefing schedule for
the parties’ cross-motions as set forth above.
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IT IS SO ORDERED.
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Dated: June 7, 2017
William H. Orrick
United States District Judge
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Stipulation to Continue Briefing Schedule
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Case No: 16-3293 WHO
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