James R Bechtold v. Hartford Life and Accident Insurance Company

Filing 29

STIPULATION AND ORDER to Modify the Scheduling Order. Signed by Judge Richard Seeborg on 4/11/17. (cl, COURT STAFF) (Filed on 4/11/2017)

1
2
3
4
5
6
7
8
9
10
11
12
13
14
15

Sean P. Nalty (SBN 121253)
[e-mail]
Shivani Nanda (SBN 253891)
[e-mail]
OGLETREE, DEAKINS, NASH, SMOAK & STEWART, P.C.
Steuart Tower, Suite 1300
One Market Plaza
San Francisco, CA 94105
Telephone:
415.442.4810
Facsimile:
415.442.4870
Attorneys for Defendant
HARTFORD LIFE AND ACCIDENT INSURANCE COMPANY
Robert J. McKennon (SBN 123176)
[e-mail]
Scott E. Calvert (SBN 210787)
[e-mail]
David S. Rankin (SBN 270326)
[e-mail]
MCKENNON LAW GROUP P.C.
20321 SW Birch Street, Suite 200
Newport Beach, CA 92660
Telephone:
949.387.9595
Facsimile:
949.385.5165
Attorneys for Plaintiff
JAMES R. BECHTOLD
UNITED STATES DISTRICT COURT

16
NORTHERN DISTRICT OF CALIFORNIA
17
SAN FRANCISCO
18
JAMES R. BECHTOLD,

Case No. 3:16-cv-04383-RS

19
Plaintiff,
STIPULATION TO MODIFY THE
SCHEDULING ORDER; [PROPOSED]
ORDER

20
v.
21
22

HARTFORD LIFE AND ACCIDENT
INSURANCE COMPANY; and DOES 1 to
10, inclusive,

23
Defendants.

Complaint Filed: August 3, 2016
Trial Date:
None Set
Judge:
Hon. Richard Seeborg

24
25
26
27
28
Case No. 3:16-cv-04383-RS
STIPULATION TO MODIFY THE SCHEDULING ORDER; [PROPOSED] ORDER

1

The Parties to the above captioned matter, plaintiff James Bechtold (“plaintiff”) and

2

defendant Hartford Life and Accident Insurance Company (“defendant”) (collectively “the

3

Parties”) hereby request that the Court modify the Scheduling Order in this matter as follows:

4
5
6

This matter is governed by the Employee Retirement Income Security Act (“ERISA”). The
opening briefs in this matter must be filed by April 20, 2017. The Parties currently are in complex
settlement negotiations and wish to extend the date for the filing of the opening brief from

7
April 20, 2017 to April 27, 2017 to allow time to complete these settlement negotiations. The
8
9
10
11

response brief still would be due May 11, 2017 and the Bench Trial in this matter still would take
place on May 22, 2017.
Accordingly, the Parties, through their counsel of record, hereby stipulate that the opening

12

brief in this matter can be filed on April 27, 2017 and the Parties respectfully request the Court

13

approve this change to the Scheduling order in this matter.

14

IT IS SO STIPULATED.

15
16

DATED: April 10, 2017

OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

17
18

By: /s/ Sean P. Nalty
Sean P. Nalty
Shivani Nanda

19
20

Attorneys for Defendant
HARTFORD LIFE AND ACCIDENT
INSURANCE COMPANY

21
22

DATED: April 10, 2017

MCKENNON LAW GROUP P.C.

23
24
25
26

By: /s/ Robert J. McKennon
Robert J. McKennon
Scott E. Calvert
David S. Rankin
Attorneys for Plaintiff
JAMES R. BECHTOLD

27
28
1
Case No. 3:16-cv-04383-RS
STIPULATION TO MODIFY THE SCHEDULING ORDER; [PROPOSED] ORDER

1
2
3

ATTESTATION
Pursuant to Local Rule 5-1(i)(1), I attest that concurrence in the filing of this document has
been obtained from each of the other signatories.

4
OGLETREE, DEAKINS, NASH, SMOAK &
STEWART, P.C.

5
6
7

Dated: April 10, 2017.

By:

8

/s/ Sean P. Nalty
Sean P. Nalty
Shivani Nanda

9
Attorneys for Defendant
HARTFORD LIFE AND ACCIDENT INSURANCE
COMPANY

10
11
12

[PROPOSED] ORDER

13
Good Cause Appearing Therefore, the Court hereby modifies the Scheduling Order in this
14
matter to make the opening briefs in this matter due on April 27, 2017. The other dates in the
15
16
17
18
19
20
21

Scheduling Order shall remain the same.
IT IS SO ORDERED.
11,
Dated: April 10, 2017.
The Honorable Richard Seeborg
U.S. District Court Judge
26577396.1

22
23
24
25
26
27
28
2
Case No. 3:16-cv-04383-RS
STIPULATION TO MODIFY THE SCHEDULING ORDER; [PROPOSED] ORDER