Rygg v. MetroPCS Wireless, Inc. Employee Welfare Benefit Plan et al

Filing 36

STIPULATION AND ORDER re 35 STIPULATION WITH PROPOSED ORDER filed by MetroPCS Wireless, Inc. Employee Welfare Benefit Plan, Life Insurance Company of North America, Inc. Signed by Judge Jon S. Tigar on November 5, 2018. (wsn, COURT STAFF) (Filed on 11/5/2018)

1 Anna Maria Martin (Bar No. 154279)
[e-mail]
2 Kristin P. Kyle de Bautista (Bar No. 221750)
[e-mail]
3 Grant Ingram (Bar No. 242785)
[e-mail]
4 MESERVE, MUMPER & HUGHES LLP
800 Wilshire Boulevard, Suite 500
5 Los Angeles, California 90017-2611
Telephone: [phone]
6 Facsimile: [phone]
7 Attorneys for Defendants
LIFE INSURANCE COMPANY OF NORTH
8 AMERICA and METROPCS WIRELESS, INC.
EMPLOYEE WELFARE BENEFIT PLAN
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Laurence F. Padway (Bar No. 89314)
10 LAW OFFICES OF LAURENCE F. PADWAY
1516 Oak Street, Suite 109
11 Alameda, California 94501
Telephone: [phone]
12 Facsimile: [phone]
13 Attorneys for Plaintiff
SONJA K. RYGG
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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18 SONJA K. RYGG,
Plaintiff,

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vs.

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21 METROPCS WIRELESS, INC.
EMPLOYEE WELFARE BENEFIT
22 PLAN, and LIFE INSURANCE
COMPANY OF NORTH AMERICA,
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Defendants.
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Case No. 3:17-cv-06891-JST
STIPULATION TO CONTINUE
BRIEFING AND HEARING
SCHEDULE ON CROSSMOTIONS FOR JUDGMENT;
[PROPOSED] ORDER THEREON
Current Date: January 24, 2019
Current Time: 2:00 p.m.
Requested Date: January 31, 2019
Requested Time: 2:00 p.m.

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LAW OFFICES

MESERVE,
MUMPER &
HUGHES LLP

167027.1

STIPULATION TO CONTINUE BRIEFING
AND HEARING SCHEDULE ON CROSSMOTIONS FOR JUDGMENT

1 TO THIS HONORABLE COURT:
WHEREAS the following briefing schedule was set by the Court on

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3 October 9, 2018, and
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Plaintiff’s Opening Brief:

October 24, 2018

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Defendant’s Opening Brief:

November 9, 2018

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Plaintiff’s Responsive Brief:

December 4, 2018

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Defendant’s Responsive Brief:

December 21, 2018

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Hearing:

January 24, 2019 @ 2:00 p.m.

WHEREAS, counsel for Defendant charged with preparing the Opening Brief

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10 has been ill with the flu for over a week, and has been and will be unable to complete
11 the review of Plaintiff’s Opening Brief and complete Defendants’ Opening Brief
12 before November 9th; and
WHEREAS, counsel for both parties have met and conferred, and agreed upon

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14 a revised schedule, which maintain the current hearing date and takes in to account
15 the calendar of both counsel and the upcoming holidays:
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Plaintiff’s Opening Brief:

October 24, 2018

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Defendant’s Opening Brief:

November 16, 2018

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Plaintiff’s Responsive Brief:

December 10, 2018

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Defendant’s Responsive Brief:

January 7, 2019

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Hearing:

January 24, 2019 @ 2:00 p.m.

IT IS HEREBY STIPULATED by and between Plaintiff and Defendant, by

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23 and through their respective attorneys of record, that with the Court’s permission the
24 following brief and hearing schedule be adopted as set forth above.
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LAW OFFICES

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MESERVE,
MUMPER &
HUGHES LLP

167027.1

STIPULATION TO CONTINUE BRIEFING
AND HEARING SCHEDULE ON CROSSMOTIONS FOR JUDGMENT

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IT IS SO STIPULATED.

2 Dated: November 2, 2018
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Anna Maria Martin
Kristin P. Kyle de Bautista
MESERVE, MUMPER & HUGHES LLP

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By:

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/s/ Kristin P. Kyle de Bautista
Kristin P. Kyle de Bautista
Attorneys for Defendant
LIFE INSURANCE COMPANY
OF NORTH AMERICA

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9 Dated: November 2, 2018
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Laurence F. Padway
LAW OFFICE OF LAURENCE F. PADWAY
By:

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Laurence F. Padway
Laurence F. Padway
Attorneys for Plaintiff
SONJA K. RYGG

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SIGNATURE ATTESTATION

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I, Kristin P. Kyle de Bautista, hereby attest that concurrence in the filing of the

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17 document has been obtained from the other signatory on this document.
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19 Dated: November 2, 2018

By:

Kristin P. Kyle de Bautista
Kristin P. Kyle de Bautista

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LAW OFFICES

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MESERVE,
MUMPER &
HUGHES LLP

167027.1

STIPULATION TO CONTINUE BRIEFING
AND HEARING SCHEDULE ON CROSSMOTIONS FOR JUDGMENT

1

[PROPOSED ORDER]
Pursuant to the stipulation of the parties, it is so ordered. The briefing and

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3 hearing schedule set forth above is hereby adopted
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5 IT IS SO ORDERED:
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November 5, 2018
7 DATED: _________________

_____________________________
Hon. Jon S. Tigar
United States District Judge

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LAW OFFICES

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MESERVE,
MUMPER &
HUGHES LLP

167027.1

STIPULATION TO CONTINUE BRIEFING
AND HEARING SCHEDULE ON CROSSMOTIONS FOR JUDGMENT