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

Filing 70

STIPULATION AND ORDER re 69 STIPULATION WITH PROPOSED ORDER TO CONTINUE FILING DEADLINE ON PLAINTIFF'S SUPPLEMENT REPLY BRIEF AND MEET & CONFER filed by Sonja K. Rygg. Signed by Judge Jon S. Tigar on April 17, 2019. (wsnS, COURT STAFF) (Filed on 4/17/2019)

Anna Maria Martin (Bar No. 154279)
1 [e-mail]
Kristin Kyle de Bautista (Bar No. 221750)
2 [e-mail]
Grant E. Ingram (Bar No. 242785)
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MESERVE, MUMPER & HUGHES LLP
4 800 Wilshire Boulevard, Suite 500
Los Angeles, California 90017-2611
5 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Defendant
7 LIFE INSURANCE COMPANY OF NORTH AMERICA
AND METROPCS WIRELESS, INC. EMPLOYEE
8 WELFARE BENEFIT PLAN
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SONJA K. RYGG,
Plaintiff,

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vs.

LIFE INSURANCE COMPANY OF NORTH
16 AMERICA AND METROPCS WIRELESS,
INC. EMPLOYEE WELFARE BENEFIT
17 PLAN,
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Defendants.

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Case No. 3:17-cv-06891-JST
STIPULATION TO CONTINUE FILING
DEADLINE ON PLAINTIFF’S
SUPPLEMENTAL REPLY BRIEF;
[PROPOSED] ORDER THEREON

Whereas, Plaintiff Sonja K. Rygg’s supplemental reply brief in response to the Court’s

21 analysis set forth in the order of February 5, 2019 (Dkt No. 55) is due on April 16, 2019. One prior
22 extension has been requested and granted;
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Whereas the Parties continue to meet and confer with regard to the questions posed by the

24 Court in its Order Requiring Supplemental Briefing (Dkt. No. 55) - (1) the specific date Rygg’s
25 eligibility for benefits ended based on her earnings at RFI Security; and (2) the amount of benefits due
26 for the relevant period;
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Whereas, counsel for Plaintiff Sonja K. Rygg has been expecting his first grandchild on or

28 about April 28th. However, the baby is arriving early and now expected this morning;
Case No. 3:17-cv-06891-JST
STIP. TO CONTINUE FILING DEADLINE ON
PLAINTIFF’S SUPPLEMENTAL REPLY
BRIEF

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Now, therefore, the parties stipulate that the briefing schedule on Ms. Rygg’s supplemental

3 reply brief in response to the Court’s analysis set forth in the order of February 5, 2019 (Dkt No.
4 55) be extended by one week so that, instead of the brief being due April 16, 2019, it will be due
5 April 23, 2019. The parties further stipulate and agree to provide the Court with a joint stipulation
6 addressing the eligibility and benefit questions posed by the Court (Dkt. No. 55) on or before April
7 23, 2019.
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IT IS HEREBY STIPULATED by and between Plaintiff and Defendant, by and through

9 their respective attorneys of record, that with the Court’s permission the following briefing
10 schedule be adopted as set forth above.
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IT IS SO STIPULATED.

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Dated: April 16, 2019

Laurence F. Padway
LAW OFFICE OF LAURENCE F. PADWAY

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By: /s/ Laurence F. Padway
Laurence F. Padway
Attorneys for Plaintiff
SONJA K. RYGG

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19 Dated: April 16, 2019
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Anna Maria Martin
Kristin Kyle de Bautista
MESERVE, MUMPER & HUGHES LLP

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By:

/s/ Anna Marie Martin
Anna Marie Martin
Kristin Kyle de Bautista
Attorneys for Defendant
LIFE INSURANCE COMPANY OF
NORTH AMERICA

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Case No. 3:17-cv-06891-JST
STIP. TO CONTINUE FILING DEADLINE ON
PLAINTIFF’S SUPPLEMENTAL REPLY
BRIEF

SIGNATURE ATTESTATION

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I, Laurence F. Padway, hereby attest that concurrence in the filing of the document has been

3 obtained from the other signatory on this document.
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Dated: April 16, 2019

By: /s/ Laurence F. Padway
Laurence F. Padway

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

10 above is hereby adopted. It is exceedingly unlikely that any further requests for extension will be
granted.
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12 IT IS SO ORDERED:
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April 17, 2019
14 DATED: _________________

_____________________________
Hon. Jon S. Tigar
United States District Judge

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Case No. 3:17-cv-06891-JST
STIP. TO CONTINUE FILING DEADLINE ON
PLAINTIFF’S SUPPLEMENTAL REPLY
BRIEF