Mullin v. American Income Life Insurance Company

Filing 32

STIPULATION AND ORDER RE 31 to Continue Dates. Jury Selection/Trial set for 7/8/2019 at 09:00 AM in San Francisco, Courtroom 03, 17th Floor before Judge Richard Seeborg. Pretrial Conference set for 6/26/2019 at 10:00 AM in San Francisco, Courtroom 03, 17th Floor before Judge Richard Seeborg. Signed by Judge Richard Seeborg on 11/8/18. (cl, COURT STAFF) (Filed on 11/8/2018)

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1 2 3 4 5 6 Glenn R. Kantor – SBN: 122643 E-mail: gkantor@kantorlaw.net Alan E. Kassan – SBN: 113864 E-mail: akantor@kantorlaw.net Andrew M. Kantor – SBN 303093 E-mail: akantor@kantorlaw.net KANTOR & KANTOR, LLP 19839 Nordhoff Street Northridge, CA 91324 Telephone: (818) 886-2525 Facsimile: (818) 350-6272 Attorneys for Plaintiff, 7 SUSAN MULLIN 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 11 SUSAN MULLIN, KANTOR & KANTOR LLP 19839 Nordhoff Street Northridge, California 91324 (818) 886 2525 12 13 CASE NO. 17-cv-05223-RS Plaintiff, STIPULATION TO CONTINUE DATES AS MODIFIED BY THE COURT vs. 14 AMERICAN INCOME LIFE INSURANCE COMPANY, 15 Defendants. 16 17 18 Plaintiff and defendants, by and through their respective counsel of record, hereby stipulate 19 as follows: 20 Whereas, the discovery cut-off date is presently set for December 7, 2018; 21 Whereas, events (deemed critical to the resolution of the case by Plaintiff) took place after 22 the filing of the Plaintiff’s complaint and Defendant’s answer, which altered the nature of the 23 dispute; 24 Whereas, additional discovery is required by both parties to properly litigate this dispute; 25 Whereas, the parties also have reignited settlement discussions and will be mediating this 26 case, and are in the process of agreeing on a mediator and satisfactory date; 27 Whereas, the parties are desirous of continuing all discovery deadlines for ninety (90) days 28 as follows: 1 STIPULATION TO CONTINUE DISCOVERY CUT OFF DATE 1 • All non-expert discovery to be completed by March 7, 2019; 2 • Parties to designate experts according to FRCP 26(a)(2) by February 5, 2019 3 • Parties to designate supplemental and rebuttal experts according to FRCP 26(a)(2) by March 7, 2019 4 • 5 Parties to complete all expert discovery according to 26(b)(4) by April 7, 2018; Whereas, the parties are further desirous of continuing the trial dates accordingly: 6 7 • Final pretrial conference to be held on May 23, 2019 June 26, 2019. 8 • Jury trial to commence on June 10, 2019 July 8, 2019. 9 10 IT IS SO STIPULATED and respectfully submitted by counsel listed below. 11 KANTOR & KANTOR LLP 19839 Nordhoff Street Northridge, California 91324 (818) 886 2525 12 Dated: KANTOR & KANTOR, LLP 13 By 14 Andrew M. Kantor Glenn R. Kantor Attorneys for Plaintiff SUSAN MULLIN 15 16 17 Dated: HINSHAW & CULBERTSON LLP 18 By: 19 Royal F. Oakes Attorneys for Defendant AMERICAN INCOME LIFE INSURANCE COMPANY 20 21 22 23 Filer’s Attestation: Pursuant to Local Rule 5-4.3.4(a)(2)(i) regarding signatures, Andrew M. 24 Kantor hereby attests that concurrence in the filing of this document and its content has been 25 obtained by all signatories listed. 26 27 28 2 STIPULATION TO CONTINUE DISCOVERY CUT OFF DATE ORDER 1 2 Having reviewed the parties’ Stipulation to Continue the Discovery Cutoff Date, and for 3 Good Cause Shown, 4 IT IS HEREBY ORDERED as follows: 5 That the cutoff date for discovery will be continued an additional ninety (90) days from 6 December 7, 2018 to March 7, 2019. 7 8 DATED: November 8, 2018 9 10 ____________________________________ Honorable Richard Seeborg U.S. District Court Judge 11 KANTOR & KANTOR LLP 19839 Nordhoff Street Northridge, California 91324 (818) 886 2525 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATION TO CONTINUE DISCOVERY CUT OFF DATE

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