Scott v. UNUM Life Insurance Company of America

Filing 40

STIPULATION AND CASE MANAGEMENT SCHEDULING ORDER: Jury Trial set for 4/18/2011 08:30 AM. Motions due by 11/16/2010. Pretrial Conference set for 4/12/2011 01:00 PM.. Signed by Judge ARMSTRONG on 9/8/10. (lrc, COURT STAFF) (Filed on 9/8/2010)

Scott v. UNUM Life Insurance Company of America

Doc. 40

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DONAHUE & HORROW, LLP

THOMAS M. HERLIHY(SBN 83615) SHEENA V. JAIN (SBN 251912) WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP 525 Market Street, 17th Floor San Francisco, California 94105-2725 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant Unum Life Insurance Company of America MICHAEL B. HORROW (SBN 162917) NICHOLE D. PODGURSKI (SBN 251240) DONAHUE & HORROW, LLP 1960 E. Grand Ave., Suite 1215 El Segundo, California 90245 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff Randolph T. Scott

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UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA RANDOLPH T. SCOTT, Plaintiff, vs. UNUM LIFE INSURANCE COMPANY OF AMERICA, Defendants. STIPULATION TO CONTINUE TRIAL AND RELATED DATES; ORDER Case No.: 4:09-cv-01841-SBA

TO THE CLERK OF COURT AND ALL PARTIES IN THE ABOVE CAPTIONED MATTER:

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STIPULATION TO CONTINUE TRIAL AND RELATED DATES

Dockets.Justia.com

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DONAHUE & HORROW, LLP

Parties in the above entitled action, plaintiff Randolph T. Scott, by and through his counsel of record, Michael Horrow of Donahue & Horrow, and defendant Unum Life Insurance Company of America, by and through its counsel of record, Thomas M. Herlihy of Wilson, Elser, Moskowitz, Edelman & Dicker LLP hereby stipulate to continue the trial in this matter, the pretrial deadlines and the hearing on dispositive motions as follows: Expert discovery Cut-off ­ October 18, 2010 Last day to hear dispositive motions (Motion Cut-off) ­ November 16, 2010 Mandatory Settlement Conference to be held between November 17, 2010 ­ January 31, 2011 Pretrial papers due ­ March 22, 2011 Motion in Limine/objections to evidence due ­ March 29, 2011 Oppositions to Motions in Limine and/or responses to objections to evidence due - April 5, 2011 Replies to Motions in Limine Due April 8, 2011 Pretrial Conference ­ April 12, 2011 at 1:00 p.m. Trial ­ April 18, 2011 at 8:30 a.m. The parties wish to continue to move the case forward, despite requesting a trial continuance to April 2011. Therefore, the parties respectfully request that the last day to hear dispositive motions be set for November 16, 2010 or for a date shortly thereafter. The disparity between the resolution of any dispositive motions and the
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STIPULATION TO CONTINUE TRIAL AND RELATED DATES

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DONAHUE & HORROW, LLP

requested continued trial date of April 18, 2011 is due to counsel's unavailability in the months prior. Further, the parties wish to have time to possibly resolve the matter following the hearing on any dispositive motions and well in advance of the trial date; therefore, the parties request that the mandatory settlement conference take place between November 17, 2010 and January 31, 2011. The parties have met and conferred extensively on these deadlines.

IT IS STIPULATED: Respectfully submitted, DONAHUE & HORROW LLP Date: September 8, 2010 /s/ Michael Horrow Michael B. Horrow Nichole D. Podgurski Attorneys for Plaintiff RANDOLPH T. SCOTT WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP By

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Date: September 8, 2010

By

/s/ Sheena Jain Thomas M. Herlihy Sheena V. Jain Attorneys for Defendant UNUM LIFE INSURANCE COMPANY OF AMERICA

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STIPULATION TO CONTINUE TRIAL AND RELATED DATES

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DONAHUE & HORROW, LLP

ORDER IT IS SO ORDERED. Date: 9/8/10 ______________________________________ Saundra B. Armstrong United States District Court Judge

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STIPULATION TO CONTINUE TRIAL AND RELATED DATES