Erina Llamas v. Life Insurance Company of North America

Filing 29

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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1 2 3 Scott Kalkin 120791 ROBOOSTOFF & KALKIN A Professional Law Corporation 369 Pine Street, Suite 820 San Francisco, California 94104 (415) 732-0282 4 Attorney for Plaintiff Erina Llamas 5 6 7 8 Anna M. Martin 154279 MESERVE, MUMPER & HUGHES LLP 800 Wilshire Boulevard, Suite 500 Los Angeles, California 90017-2611 (213) 620-0300 9 10 Attorneys for Defendant Life Insurance Company of North America 11 12 13 IN THE UNITED STATES DISTRICT COURT 14 FOR THE NORTHERN DISTRICT OF CALIFORNIA 15 16 Erina Llamas, 17 ) ) ) ) ) ) ) ) ) ) ) Plaintiff, 18 v. 19 Life Insurance Company of North America, 20 Defendant. 21 ACTION NO.: 16-cv-3293 WHO STIPULATION AND ORDER ORDER TO CONTINUE BRIEFING BRIEFING SCHEDULE FOR CROSS-MOTIONS FOR SUMMARY JUDGMENT 22 It is hereby stipulated by and between the parties through their respective counsel that 23 Plaintiff Erina Llamas and Defendant Life Insurance Company of North America may have 24 additional time within which to file the administrative record and the their respective cross- 25 motions for summary judgment in this matter. 26 Pursuant to Local Rule 6-1(b) the parties submit this request to continue the briefing 27 28 Stipulation to Continue Briefing Schedule 1 Case No: 16-3293 WHO 1 2 3 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. 4 During the course of briefing this matter plaintiff’s counsel discovered that the 5 administrative record provided to him by defense counsel may not be complete. There are 6 nine hundred and ninety five (995) pages potentially at issue, but without reviewing and 7 comparing each document at issue, it is difficult to be certain. 8 Counsel discussed this matter on June 5, 2017, and are attempting to sort this issue 9 out with an eye toward providing the Court with one set of documents to review rather than 10 two. This will facilitate both counsels’ citation to the record in their respective briefs and make 11 the court’s review of the same more efficient. 12 13 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. 14 Additionally, during the course of discussing the issues surrounding the administrative 15 record, counsel reopened their settlement negotiations and both sides would like additional 16 time to re-consider their respective positions. 17 18 19 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: 20 Schedule Current Dates Stipulated New Dates 21 Opening Brief Due June 7, 2017 July 5, 2017 22 Opposition Briefs Due June 28, 2017 July 26, 2017 23 Reply Briefs Due July 5, 2017 August 2, 2017 24 Hearing Date July 19, 2017 August 23, 2017 25 This document is being filed through the Court’s ECF system. In this regard, counsel 26 for plaintiff hereby attests that: 1) the content of this document is acceptable to all persons 27 28 Stipulation to Continue Briefing Schedule 2 Case No: 16-3293 WHO 1 required to sign it; 2) defendant has concurred in the filing of this document; and 3) a record 2 supporting this concurrence is available for inspection or production if so ordered. 3 Respectfully submitted, 4 ROBOOSTOFF & KALKIN 5 6 7 Dated: June 6, 2017 By: 8 /s Scott Kalkin Attorneys for Plaintiff 9 MESERVE, MUMPER & HUGHES LLP 10 11 Dated: June 6, 2017 12 13 By: /s Anna M. Martin Attorneys for Defendant Life Insurance Company of North America 14 15 16 17 [PROPOSED] ORDER Good cause having been shown, the Court hereby continues the briefing schedule for the parties’ cross-motions as set forth above. 18 19 IT IS SO ORDERED. 20 21 Dated: June 7, 2017 William H. Orrick United States District Judge 22 23 24 25 26 27 28 Stipulation to Continue Briefing Schedule 3 Case No: 16-3293 WHO

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