Bushee v. Liberty Life Assurance Company Of Boston

Filing 15

ORDER Granting 14 First Stipulation to Extend Certain Deadlines. Last day to file Joint Administrative Record and Joint Statement: 9/4/2018. Signed by Magistrate Judge Cam Ferenbach on 8/30/2018. (Copies have been distributed pursuant to the NEF - SLD)

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JULIE A. MERSCH, ESQ.
Nevada Bar No. 004695
LAW OFFICE OF JULIE A. MERSCH
701 S.7th Street
Las Vegas, NV 89101
[phone]
Fax: [phone]
[e-mail]

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Attorney for Plaintiff

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Georlen Spangler, Esq.
Nevada Bar No. 3818
LAW OFFICE OF GEORLEN K. SPANGLER
2620 Regatta Drive, Suite 102
Las Vegas, Nevada 89128
Phone: [phone]
E-Mail: [e-mail]
Attorneys for Defendant

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Admitted Pro Hac Vice
Iwana Rademaekers, TX Bar No. 16452560
LAW OFFICES OF IWANA RADEMAEKERS, P.C.
14785 Preston Road, Suite 550
Dallas, Texas 75254
Main: [phone]
Fax: [phone]
Email: [e-mail]

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Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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TATIANA BUSHEE,

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Plaintiff,

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v.

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LIBERTY LIFE ASSURANCE
COMPANY OF BOSTON as Claims
Administrator for the Safeway, Inc. Group
Disability Income Plan; DOES I through
V; and ROE CORPORATIONS I through
V, inclusive,

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Case No. 2:18-CV-00804-GMN-VCF

Defendant.

STIPULATION AND ORDER TO
EXTEND CERTAIN DEADLINES
FIRST REQUEST

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IT IS HEREBY STIPULATED by the parties hereto, by and through their undersigned

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counsel that, pursuant to LR 26-4, certain deadlines entered by the Court during the Hearing on

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July 5, 2018, be amended as follows:

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Certain documents were requested by Plaintiff to be added to the Administrative Record.
Defendant does not object to the inclusion of these additional documents to the Record and

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Defendant’s counsel is in the process of obtaining these documents and requires additional time
to do so. As such, the Parties are unable to file a complete Administrative Record at this time.

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Additionally, until such time as Plaintiff can review these additional documents being gathered

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by Defendant, the Parties cannot make an accurate representation to the court in their Joint

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Statement regarding unresolved issues. Accordingly, the parties request the following revisions

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to the current schedule:

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PROPOSED SCHEDULE

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Deadline

Current

Proposed

Last day to file Joint Administrative Record

Aug. 29, 2018

Sept. 4, 2018

Last day to file Joint Statement

Aug. 29, 2018

Sept. 4, 2018

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We, the undersigned, agree to the proposed scheduling as indicated above. We, the

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undersigned, also represent to the Court that we are working together cooperatively and in good

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faith to resolve the issues described above. The extension of these deadlines will not affect any

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other deadlines previously set by the Court.

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DATED this 29th day of August 2018.

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LAW OFFICE OF JULIE A. MERSCH

LAW OFFICES OF IWANA
RADEMAEKERS, P.C.

/s/ Julie A. Mersch
Julie A. Mersch, Nevada Bar No. 004695
701 S.7th Street
Las Vegas, NV 89101
Email: [e-mail]

/s/ Iwana Rademaekers
Iwana Rademaekers, TX Bar No. 16452560
Admitted Pro Hac Vice
14785 Preston Rd, Suite 550
Dallas, Texas 75254

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Attorneys for Plaintiff
- AND -

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LAW OFFICE OF GEORLEN K.
SPANGLER

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/s/ Georlen Spangler
Georlen Spangler, Nevada Bar No. 3818
2620 Regatta Drive, Suite 102
Las Vegas, Nevada 89128
Phone: [phone]

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Attorneys for Defendant Liberty Life
Assurance Company of Boston

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ORDER

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IT IS SO ORDERED

August 30

, 2018.

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United States Magistrate Judge

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