Doe v. AT&T Western Disability Benefits Program

Filing 45

ORDER on 44 STIPULATION AND PROPOSED ORDER TO STAY DISCOVERY AND MODIFY DATES, Motions terminated: 44 STIPULATION WITH PROPOSED ORDER. Fact Discovery Cutoff extended to 6/22/2012. Motions due by 7/5/2012. Motion Hearing set for 8/9/2012 11:00 AM. Pretrial Conference set for 9/19/2012 03:00 PM. Signed by Magistrate Judge Donna M. Ryu on 5/25/2012. (hlkS, COURT STAFF) (Filed on 5/25/2012)

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THERESA M. CABREROS (State Bar No. 212740)
AT&T SERVICES, INC. LEGAL DEPARTMENT
525 Market Street, Suite 2021
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorney for Defendant
AT&T UMBRELLA BENEFIT PLAN NO. 1

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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OAKLAND DIVISION
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JOHN DOE,

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Plaintiff,

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Case No. C11-04603 DMR

vs.

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STIPULATION AND PROPOSED
ORDER TO STAY DISCOVERY AND
MODIFY DATES

AT&T UMBRELLA BENEFIT PLAN NO.1

Judge: Magistrate Judge Ryu

Defendant.

Amended Complaint filed: October 19, 2011

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Stipulation to Stay Discovery and Modify
Dates; Case # C11-04603 DMR

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This Stipulation is entered into by and among Plaintiff John Doe (“Plaintiff”),

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Defendant AT&T UMBRELLA BENEFIT PLAN NO. 1 (“Defendant”), by and through their

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respective counsel.

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WHEREAS Plaintiff filed his First Amended Complaint on October 19, 2011.

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WHEREAS Defendant filed its Answer to the First Amended Complaint on December

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16, 2011.
WHEREAS the parties are currently in the process of informal good faith settlement
negotiations.
WHEREAS the parties are interested in limiting the accrual of fees and costs during

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settlement negotiations to the extent possible, as the incurrence of additional fees and costs may

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impede the resolution of this matter.

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WHEREAS, should the parties fail to resolve this matter informally, they are scheduled

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to attend a settlement conference with Magistrate Judge Jacqueline Scott Corley on June 5,

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2012 at 10:30 a.m.

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WHEREAS the parties have agreed to stay all discovery until the conclusion of the June
5, 2012 settlement conference.
WHEREAS the parties propose to modify the current case schedule as follows to

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accommodate a brief stay of discovery:

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Currently Scheduled Dates

Proposed Modified Scheduled Dates

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Fact Discovery Cutoff: 6/8/2012

Fact Discovery Cutoff: 6/22/2012

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Motions for Summary Judgment: 6/21/2012

Motions for Summary Judgment: 7/5/2012

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Hearing on Summary Judgment: 7/26/2012

Hearing on Summary Judgment: 8/9/2012

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Pretrial Meet and Confer: 7/23/2010

Pretrial Meet and Confer: 8/16/2012

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Joint Pre-Trial Stmt/Trial Briefs: 8/2/2102

Joint Pre-Trial Stmt/Trial Briefs: 8/30/2012

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Pre-Trial Objections: 8/13/2012

Pre-Trial Objections: 9/10/2012

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Pre-Trial Conference: 8/22/2012

Pre-Trial Conference: 9/19/2012

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Trial: 10/1/2012

Trial: 10/1/2012 (no change)

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Stipulation to Stay Discovery and Modify
Dates; Case # C11-04603 DMR

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IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned
counsel for Plaintiff and Defendant, as follows:

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1. All discovery is stayed until the conclusion of the June 5, 2012 settlement conference.

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2. Should the parties fail to resolve the dispute upon the conclusion of the settlement

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conference, they shall be prepared to proceed with litigation as set forth above in the

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proposed modified scheduled dates.

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Respectfully Submitted,

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Dated: May 24, 2012

AT&T Services Legal Department

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/s/ Theresa M. Cabreros___________
Theresa M. Cabreros
Attorney for Defendant

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Dated: May 24, 2012

Lewis, Feinberg, Lee, Renaker & Jackson

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/s/ Lindsay Nako_________________
Lindsay Nako
Attorneys for Plaintiff

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PURSUANT TO THE STIPULATION OF THE PARTIES, IT IS SO ORDERED.

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Stipulation to Stay Discovery and Modify
Dates; Case # C11-04603 DMR

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R NIA

__________________________________
Honorable Donna M. Ryu ED
ORDER
United States O
IS S Magistrate Judge
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Dated: May 25, 2012
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FILER’S ATTESTATION

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Pursuant to General Order No. 45, Section X, Subparagraph B, the undersigned attests

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that all parties have concurred in the filing of the Stipulation to Stay Discovery and Modify

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Dates.

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Dated: May 24, 2012

AT&T Services Legal Department

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/s/ Theresa M. Cabreros_______________
Theresa M. Cabreros

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Stipulation to Stay Discovery and Modify
Dates; Case # C11-04603 DMR

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