Mujadadi-Turan v. Motorola Mobility, LLC et al

Filing 28

ORDER GRANTING 25 Stipulation to Continue Deadline For Metlife To Respond To Plaintiffs Complaint filed by Metropolitan Life Insurance Company. Response due 11/10/2015. Signed by Judge Edward J. Davila on 10/15/2015. (ecg, COURT STAFF) (Filed on 10/15/2015)

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d w a rd
J u d ge E

J . D av i l

Attorneys for Plaintiff
NIA MUJADADI-TURAN

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E R DATED: 10/15/2015 C
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ERED

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IT IS S

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GLENN KANTOR (SBN 122643)
[e-mail]
BETH A. DAVIS (SBN 277560)
[e-mail]
ANDREW KANTOR (SBN 303093)
[e-mail]
KANTOR & KANTOR, LLP
19839 Nordhoff Street
Northridge, CA 91324
Telephone: [phone]
Facsimile: [phone]

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S DISTRICT
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R NIA

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Attorneys for Defendant
METROPOLITAN LIFE INSURANCE COMPANY

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C. ANDREW KITCHEN (SBN 292609)
[e-mail]
ALEXANDRA V. DRURY (SBN 291920)
[e-mail]
MAYNARD, COOPER, & GALE, LLP
275 Battery Street, Suite 1350
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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NIA MUJADADI-TURAN

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Plaintiff,
vs.

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MOTOROLA MOBILITY, LLC;
METROPOLITAN LIFE INSURANCE
COMPANY

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Defendants.
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Case No.: 05:15-cv-2752-EJD
Hon. Edward J. Davila
JOINT STIPULATION TO CONTINUE
DEADLINE FOR METLIFE TO
RESPOND TO PLAINTIFF’S
COMPLAINT
Complaint Filed:
Trial Date:

June 18, 2015
TBD

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JOINT STIPULATION TO CONTINUE DEADLINE FOR METLIFE TO RESPOND TO
PLAINTIFF’S COMPLAINT

03404470.2

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JOINT STIPULATION

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Pursuant to Civil Local Rule 6-1, Plaintiff Nia Mujadadi-Turan (“Plaintiff”) and

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Defendant Metropolitan Life Insurance Company (“MetLife”), hereby jointly stipulate to an

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extension of time for MetLife to respond to Plaintiff’s Complaint. The Parties agree and

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stipulate that MetLife will respond to Plaintiff’s Complaint on or before November 10, 2015.

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In support of this Stipulation, the Parties agree and stipulate as follows:

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1.

On June 18, 2015, Plaintiff initiated the present action against MetLife in the

United States District Court for the Northern District of California. (See ECF Doc. No. 1).

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2.

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26, 2015.

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3.

MetLife was served with the Summons and Complaint in this action on June

The parties submitted stipulations extending the deadline for MetLife to

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respond to the Complaint to facilitate on-going settlement discussions. (See ECF Doc. Nos.

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11, 14 and 20).

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4.

The Parties have agreed to an additional thirty (30) day extension of time for

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MetLife to respond to Plaintiff’s Complaint. Accordingly, based on the stipulation, MetLife’s

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response to Plaintiff’s Complaint is due on or before November 10, 2015.

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5.

The Parties are optimistic that a resolution can be reached in this matter, and

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the additional time will afford the Parties the opportunity to explore settlement opportunities

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without incurring additional costs of litigation. This Stipulation will not alter the date of any

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event or deadline already fixed by Court order. Therefore, the Parties stipulate and agree to

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extend MetLife’s deadline to respond to Plaintiff’s Complaint until November 10, 2015.

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JOINT STIPULATION TO CONTINUE DEADLINE FOR METLIFE TO RESPOND TO
PLAINTIFF’S COMPLAINT

03404470.2

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Date: October 9, 2015

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MAYNARD, COOPER, & GALE, LLP
By: /s/ C. Andrew Kitchen
C. Andrew Kitchen
Attorneys for Defendant
METROPOLITAN LIFE INSURANCE
COMPANY

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Date: October 9, 2015

KANTOR & KANTOR LLP

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By: /s/ Beth A. Davis
BETH A. DAVIS
Attorneys for Plaintiff
NIA MUJADADI-TURAN

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JOINT STIPULATION TO CONTINUE DEADLINE FOR METLIFE TO RESPOND TO
PLAINTIFF’S COMPLAINT

03404470.2

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CERTIFICATE OF SERVICE

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I am employed in the County of San Francisco State of California. I am over the age of
eighteen years and not a party to this action. My business address is 275 Battery Street, Suite
1350, San Francisco, CA 94111. On September 10, 2015, I served a copy of the following
documents:

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JOINT STIPULATION TO CONTINUE DEADLINE FOR METLIFE TO RESPOND
TO PLAINTIFF’S COMPLAINT

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[x]
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By CM/ECF ELECTRONIC SERVICE: The following are registered CM/ECF users
with the Court, and have consented to service through the Court’s automatic transmission
of a notice of electronic filing.

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GLENN KANTOR (SBN 122643)
[e-mail]
BETH A. DAVIS (SBN 277560)
[e-mail]
ANDREW KANTOR (SBN 303093)
[e-mail]
KANTOR & KANTOR, LLP
19839 Nordhoff Street
Northridge, CA 91324
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff NIA MUJADADI-TURAN

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Benjamin A. Emmert
[e-mail]
LITTLER MENDELSON
50 West San Fernando Street, 15th Floor
San Jose, CA 95113-2431
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Defendant MOTOROLA MOBILITY, LLC

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I declare under penalty of perjury under the laws of the United States of America that
the foregoing is true and correct to the best of my knowledge.

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Executed on October 9, 2015, at San Francisco, California.
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_______________________________
Mila Dunn

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JOINT STIPULATION TO CONTINUE DEADLINE FOR METLIFE TO RESPOND TO
PLAINTIFF’S COMPLAINT

03404470.2