Naser v. Metropolitan Life Insurance Company et al

Filing 70

Order Granting 69 Stipulation re Plaintiff's Time to File Motion for Summary Judgment. Signed by Hon. Edward J. Davila on 11/20/2012.(ecg, COURT STAFF) (Filed on 11/20/2012)

1

2
3
4
5
6
7

8
9

RICHARD B. GLICKMAN (SB# 47898)
[e-mail]
RICHARD B. GLICKMAN A PROFESSIONAL CORP.
One Maritime Plaza, Suite 1600
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
BARBARA GIUFFRE (SB#158180)
[e-mail]
WORK/ENVIRONMENT LAW GROUP
351 California Street, Suite 700
San Francisco, CA 94104
Telephone: [phone]
Facsimile: [phone]
Co-Counsel for Plaintiff
LOA Y S. NASER

10
11
UNITED STATES DISTRICT COURT
12
NORTHERN DISTRICT OF CALIFORNIA

13
SAN JOSE DIVISION

14
15
CASE NO. 5:10-CV-04475-EJD

LOA Y S. NASER,

16

XXXXXXXX
STIPULATION AND [PROPOSED] ORDER
RE PLAINTIFF'S TIME TO FILE MOTION
FOR SUMMARY JUDGMENT

Plaintiff,

17
VS.

18
METROPOLITAN LIFE INSURANCE

19 II COMPANY, METLIFE ENTERPRISE
GENERAL INSURANCE AGENCY, INC.

20 II AND METLIFE SECURITIES,
21 II

Defendants.

22
23
24

PlaintiffLOAY
METROPOLITAN

S. NASER ("Naser")

LIFE INSURANCE

and Defendants

COMPANY,

METLIFE ENTERPRISE

25

26

GENERAL

INSURANCE

27

(collectively

"MetLife"),

AGENCY,

INC., AND METLIFE

SECURITIES

by and through their attorneys of record, hereby stipulate

28
STIPULATION

AND PROPOSED ORDER

1

as follows:

2
WHEREAS

by Pretrial Order dated July 3, 2012, the above-noted

3
4

Court ordered that all summary judgment

5

motions must be filed by November

23,

2012;

6
WHEREAS

documents needed by Naser for his summary judgment

7
8

motion were not produced to him until the middle of his deposition on November

9

16,2012,

at which time he received a disk containing more than 700 pages of

10
documents;
11
WHEREAS

12
13

the transcript of Naser's November

also needed by him for his summary judgment

16,2012

deposition,

motion, was not available until

14
15
16
17

today; and
WHEREAS

the hearing on Naser's

was scheduled with Courtroom

summary judgment

Clerk Elizabeth Garcia on November

motion, which
13,2012

for

18
19
20
21

the first available date, will not be heard until February
NOW, THEREFORE,

15,2013;

it is hereby stipulated and agreed to, by and

between all parties to the above-captioned

action (i.e., Naser and MetLife), that

22
23

24

subject to this Court's approval Naser may have a five (5) day extension -- until and
including November

28, 2012 -- to file his motion for summary judgment.

25
26
27
28
Case No. 5:10-cv-4475-EID

1

STIPULATION AND PROPOSED ORDER

1

2

DATED: November 19,2012

3
Richard B. Glickman
RICHARD B. GLICKMAN A PROFESSIONAL CORP.

4

5

Barbara Giuffre
WORK/ENVIRONMENT

6

LAW GROUP

Co-Counsel for Plaintiff
Loay S. Naser

7
8

9

Dated: November 19,2012

10

By:

/s/
Rachel B. Cowen
DLA PIPER LLP (US)

Counsel for All Defendants

11
12
13

GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that Plaintiff Naser's time to file a

14

summary judgment motion is extended until and including November 28,2012. The anticipated
hearing on the Motion for Summary Judgment is continued from February 15, 2013 to March 1, 2013
15
Dated: November __
20 , 2012

16
17
United States District Judge

18
19
20
21

22
23
24
25
26

27

28
Case No. 5:10-cv-4475-EID

2

STIPULATION

AND PROPOSED ORDER