Geraghty v. Prudential Insurance Company of America et al

Filing 26

STIPULATION AND ORDER re 24 STIPULATION WITH PROPOSED ORDER [STIPULATION AND REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED CASE DEADLINES; [PROPOSED] ORDER filed by Prudential Insurance Company of America. Case Management Statement due by 4/11/2018. Initial Case Management Conference set for 4/18/2018 at 2:00 PM in Courtroom 9, 19th Floor, San Francisco. Signed by Judge Jon S. Tigar on January 11, 2018. (wsn, COURT STAFF) (Filed on 1/12/2018)

Download PDF
1 2 3 4 LAFAYETTE & KUMAGAI LLP GARY T. LAFAYETTE (SBN 88666) BRIAN H. CHUN (SBN 215417) 1300 Clay Street, Suite 810 Oakland, California 94612 Telephone: (415) 357-4600 Facsimile: (415) 357-4605 5 6 7 Attorneys for Defendant THE PRUDENTIAL INSURANCE COMPANY OF AMERICA 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 COLLEEN GERAGHTY, (415) 357-4600 (415) 357-4605 12 FAX 810 94612 CLAY STREET, SUITE ATTORNEYS AT LAW OAKLAND, CALIFORNIA 1300 LAFAYETTE & KUMAGAI LLP 11 13 14 15 16 17 Case No. 3:17-cv-06006-JST Plaintiff, v. THE PRUDENTIAL INSURANCE COMPANY OF AMERICA; PRUCO SECURITIES; RYAN MOONEY, and DOES 1 to 10, STIPULATION AND REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED CASE DEADLINES; [PROPOSED] ORDER Complaint Filed: October 19, 2017 Defendants. 18 19 20 21 STIPULATION AND REQUEST Plaintiff Colleen Geraghty (“Plaintiff”) and Defendant The Prudential Insurance 22 Company of America (“Defendant”) (collectively, the “Parties”) through their respective counsel 23 hereby stipulate as follows: 24 25 WHEREAS the last day for Defendant to file a response to Plaintiff’s Complaint is January 17, 2018; 26 WHEREAS the Standing Order for Certain Employment Cases Pending Before United 27 States District Judge Jon S. Tigar (Document 17-2) (“Standing Order”) requires that the parties 28 produce certain documents and information within 30 days following Defendant’s submission of STIPULATION AND REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED CASE DEADLINES; [PROPOSED] ORDER (Case No. 3:17-cv-06006-JST) 1 1 a responsive pleading or motion, i.e., by February 16, 2018; 2 WHEREAS the Standing Order further provides that “[t]he parties shall use the 3 documents and information exchanged in accordance with the Initial Discovery Protocols to 4 prepare the F.R.C.P. 26(f) discovery plan”; 5 6 WHEREAS Defendant needs an additional three weeks beyond February 16, 2018 to comply with the Standing Order’s required production of documents and information; 7 8 WHEREAS the deadline for the Parties to participate in a Rule 26(f) conference was January 3, 2018; 9 10 WHEREAS a Joint Case Management Statement, which will include the Parties’ discovery plan, is currently due on January 16, 2018; (415) 357-4600 (415) 357-4605 12 FAX 810 94612 CLAY STREET, SUITE ATTORNEYS AT LAW OAKLAND, CALIFORNIA 1300 LAFAYETTE & KUMAGAI LLP 11 13 WHEREAS a Case Management Conference is currently scheduled for January 24, 2018; and; WHEREAS in order to comply with the Standing Order’s requirement that the parties use 14 the documents and information exchanged in accordance with the Initial Discovery Protocols to 15 prepare a discovery plan, the Parties agree that a continuance of the Case Management 16 Conference is necessary; 17 NOW, THEREFORE, IT IS HEREBY STIPULATED AND REQUESTED by and 18 between the Parties through their respective attorneys of record that (1) the deadline for the 19 Parties to produce certain documents and information pursuant to the Initial Discovery Protocols 20 be extended to March 9, 2018, (2) the deadline for the Parties to participate in a Rule 26(f) 21 conference be continued to March 28, 2018; (3) the deadline for the Parties to file a Joint Case 22 Management Statement be continued to April 11, 2018, and (4) the Case Management 23 Conference be continued to April 18, 2018. 24 25 DATED: January 10, 2018 BROWN POORE LLP 26 27 28 /s/ David M. Poore DAVID M. POORE Attorneys for Plaintiff COLLEEN GERAGHTY STIPULATION AND REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED CASE DEADLINES; [PROPOSED] ORDER (Case No. 3:17-cv-06006-JST) 2 1 DATED: January 10, 2018 LAFAYETTE & KUMAGAI LLP 2 /s/ Gary T. Lafayette GARY T. LAFAYETTE Attorney for Defendant THE PRUDENTIAL INSURANCE COMPANY OF AMERICA 3 4 5 6 7 SIGNATURE ATTESTATION 8 I hereby attest that I have obtained the concurrence of David M. Poore, counsel for 9 Plaintiff, for the filing of this stipulation. 10 /s/ Gary T. Lafayette GARY T. LAFAYETTE (415) 357-4600 (415) 357-4605 12 FAX 810 94612 CLAY STREET, SUITE ATTORNEYS AT LAW OAKLAND, CALIFORNIA 1300 LAFAYETTE & KUMAGAI LLP 11 13 14 ORDER Good cause appearing therefor and pursuant to the parties’ stipulation, it is hereby 15 ORDERED that (1) the deadline for the Parties to produce certain documents and information 16 pursuant to the Initial Discovery Protocols is extended to March 9, 2018, (2) the deadline for the 17 Parties to participate in a Rule 26(f) conference is continued to March 28, 2018; (3) the deadline 18 for the Parties to file a Joint Case Management Statement is continued to April 11, 2018, and (4) 19 the Case Management Conference is continued to April 18, 2018 at 2:00 p.m. 20 PURSUANT TO STIPULATION, IT IS SO ORDERED. 21 22 23 DATED: January 11 , 2018 JON S. TIGAR United States District Judge 24 25 26 27 28 STIPULATION AND REQUEST TO CONTINUE CASE MANAGEMENT CONFERENCE AND RELATED CASE DEADLINES; [PROPOSED] ORDER (Case No. 3:17-cv-06006-JST) 3

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?