Abraham Ghorbanian v. Guardian Life Insurance Company of America et al

Filing 87

ORDER by Judge Ricardo S Martinez re 86 Unopposed Motion for Extension of Time re Noting Date and Briefing Schedule Regarding Defendants' Motion to Dismiss. Noting date on Defendants' 81 MOTION for Sanctions for Spoliation Including Dismissal is continued to April 14, 2017. (swt)

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THE HONORABLE RICARDO S. MARTINEZ 1 2 3 4 5 6 7 8 IN THE UNITED STATES DISTRICT COURT DONAHUE & HORROW, LLP 9 FOR THE WESTERN DISTRICT OF WASHINGTON AT SEATTLE 10 11 12 ABRAHAM GHORBANIAN, D.D.S. Plaintiff, 13 14 15 16 17 vs. GUARDIAN LIFE INSURANCE COMPANY OF AMERICA, BERKSHIRE LIFE INSURANCE COMPANY OF AMERICA and DOES 1 THROUGH 10, Case No. 2:14-CV-01396-RSM UNOPPOSED REQUEST TO EXTEND THE NOTING DATE AND BRIEFING SCHEDULE REGARDING DEFENDANTS’ MOTION TO DISMISS AND ORDER Defendants. 18 19 20 Plaintiff Abraham Ghorbanian, D.D.S., by his undersigned counsel, respectfully moves the 21 Court to extend the noting date for Defendants Guardian Life Insurance Company of America 22 (“Guardian”) and Berkshire Life Insurance Company of America’s (“Berkshire”) (“collectively 23 referred to as “Defendants”) Motion for Spoliation Sanctions, Including Dismissal. This 24 Motion is currently noted on the Motion Calendar for March 24, 2017. Plaintiff respectfully 25 requests that the Noting Date on this motion be extended to April 14, 2017. 26 27 28 UNOPPOSED MOTION TO EXTEND NOTING DATE FOR DEFENDANTS’ MOTION TO DISMISS AND ORDER Case No.: 2:14-CV-01396-RSM Page 1 Donahue & Horrow, LLP 1960 E. Grand Ave. Suite 1215 El Segundo, CA 90245 T: (310) 322-0300 F: (310) 322-0302 1 As grounds for this request Plaintiff states that the request is being made as counsel have 2 travel commitments and scheduling conflicts with respect to this case and other cases making it 3 difficult to meet the deadlines imposed under the March 24, 2017 Noting Date and, in response 4 to this Motion, Plaintiff is contemplating obtaining declarations from various third parties who 5 may be unavailable before the time Plaintiff’s opposition is due under the March 24, 2017 6 noting date. 7 This request is being made in good faith and not for the purposes of delay. Extending the Noting Date to April 14, 2017 does not have an effect on any of the other case deadlines. 9 DONAHUE & HORROW, LLP 8 Finally, Defendants have no opposition to the continuance of the Noting Date to April 14, 2017. 10 Therefore, Plaintiff respectfully requests that the Noting Date and all related deadlines for 11 Defendants’ Motion for Spoliation Sanctions, including Dismissal, be continued from March 24, 12 2017 to April 14, 2017. 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Dated this 10th day of March, 2017. By :/s/ Michael B. Horrow Michael B. Horrow, Admitted Pro Hac Vice Nichole D. Podgurski, Admitted Pro Hac Vice Donahue & Horrow, LLP 1960 E. Grand Ave., Suite 1215 El Segundo, California 90245 Phone: 310-322-0300 Fax: 310-322-0302 Email: mhorrow@donahuehorrow.com npodgurski@donahuehorrow.com Kenneth Friedman, (WSBA 17148) Friedman Rubin & White 1126 Highland Avenue Bremerton, WA 98337 Phone: 360-782-4300 Fax: 360-782-4358 Email: kfriedman@friedmanrubin.com Attorneys for Plaintiff 27 28 UNOPPOSED MOTION TO EXTEND NOTING DATE FOR DEFENDANTS’ MOTION TO DISMISS AND ORDER Case No.: 2:14-CV-01396-RSM Page 2 Donahue & Horrow, LLP 1960 E. Grand Ave. Suite 1215 El Segundo, CA 90245 T: (310) 322-0300 F: (310) 322-0302 1 ORDER 2 Based on the above Unopposed Request to Extend the Noting Date for Defendants’ 3 Motion for Spoliation Sanctions, Including Dismissal, and for good cause shown, IT IS SO 4 ORDERED that the Noting date on Defendants’ Motion for Spoliation Sanctions is continued to 5 April 14, 2017. 6 DATED this 13 day of March 2017. 7 8 DONAHUE & HORROW, LLP 9 A 10 11 12 RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 UNOPPOSED MOTION TO EXTEND NOTING DATE FOR DEFENDANTS’ MOTION TO DISMISS AND ORDER Case No.: 2:14-CV-01396-RSM Page 3 Donahue & Horrow, LLP 1960 E. Grand Ave. Suite 1215 El Segundo, CA 90245 T: (310) 322-0300 F: (310) 322-0302

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