Ramos v. Bank of America et al

Filing 39

STIPULATION AND ORDER TO CONTINUE DISCOVERY DATES AND DEADLINES re 38 Stipulation filed by Bank of America Long Term Disability Plan, Metropolitan Life Insurance Company. Signed by Judge Phyllis J. Hamilton on 4/20/09. (nah, COURT STAFF) (Filed on 4/20/2009)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SF/1585394v1 SEDGWICK, DETERT, MORAN & ARNOLD LLP REBECCA A. HULL Bar No. 99802 MICHELLE Y. MCISAAC Bar No. 215294 One Market Plaza Steuart Tower, 8th Floor San Francisco, California 94105 Telephone: (415) 781-7900 Facsimile: (415) 781-2635 Attorneys for Defendants Metropolitan Life Insurance Company and Bank of America Long Term Disability Benefits Plan (erroneously sued as Bank of America Long Term Disability Plan) UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA LENA MONZON RAMOS, Plaintiff, v. BANK OF AMERICA; METROPOLITAN LIFE INSURANCE COMPANY; BANK OF AMERICA LONG TERM DISABILITY PLAN, Defendants. CASE NO. CV 08-01375 PJH STIPULATION AND [PROPOSED] ORDER TO CONTINUE DISCOVERY DATES AND DEADLINES Defendants Metropolitan Life Insurance Company ("MetLife"), Bank of America Long Term Disability Benefits Plan ("Plans" herein), Bank of America Group Benefits Program ("BofA"), and plaintiff Lena Monzon Ramos, by and through their respective attorneys of record, hereby agree and stipulate as follows: 1. Pursuant to Stipulation and Court Order, it was agreed that it would be in the interests of all parties, and consistent with judicial economy, for the potential discovery and related issues, as well as substantive motions, be deferred while the parties attempted to mediate their disputes. 2. It was further agreed that if the mediation was not successful, a period of 120 days thereafter, should be sufficient time in which to conduct any necessary discovery procedures, -1CASE NO. CV 08-01375 PJH STIPULATION AND [PROPOSED] ORDER TO CONTINUE DISCOVERY DATES AND DEADLINES 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 SF/1585394v1 including potential motions. 3. 4. A mediation was held on January 23, 2009, which was unsuccessful. The parties have agreed that additional time is needed for plaintiff to file her motion to compel discovery, due to the current illness of her counsel. WHEREFORE, the parties, by and through their respective counsel stipulate, and request that the Court order, as follows: STIPULATION The parties agree that plaintiff's motion to compel discovery, if any, will be filed on or before May 7, 2009, and will be noticed for hearing not earlier than June 25, 2009. IT IS SO STIPULATED. DATED: April 16, 2009 SEDGWICK, DETERT, MORAN & ARNOLD LLP By: /s/ Rebecca A. Hull Rebecca A. Hull Michelle Y. McIsaac Attorneys for Defendants Metropolitan Life Insurance Company and Bank of America Long Term Disability Benefits Plan DATED: April 16, 2009 THE LAW OFFICE OF JOSEPH A. CREITZ, P.C. LAW OFFICE OF JOSEPH A. GAROFOLO, P.C. By: /s/ Joseph A. Creitz Joseph A. Creitz Attorneys for Plaintiff Lena Monzon Ramos ORDER Upon the stipulation of the parties, and good cause appearing, IT IS SO ORDERED. DATED: 4/20/09 UNIT ED S DISTRICT TE C TA RT U O S -2CASE NO. CV 08-01375 PJH ER C N F D IS T IC T O STIPULATION AND [PROPOSED] ORDER TO R CONTINUE DISCOVERY DATES AND DEADLINES H A LI FO UNITED STATES DISTRICT COURT JUDGE amilton H h Judge P yllis J. R NIA IT IS S O ORD ERED NO RT

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