Opinion
Case No.: CV09-00532-GEB (KIN)
09-12-2011
RELIANCE STANDARD LIFE INSURANCE COMPANY, Plaintiff, v. CHARLIE A. HARRISON, Defendant
ADRIENNE C. PUBLICOVER (SBN 161432) DENNIS J. RHODES (SBN 168417) WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP Attorneys for Plaintiff RELIANCE STANDARD LIFE INSURANCE COMPANY MICHAEL COGAN, ESQ. GENE TUCKER, ESQ. Attorney for Defendant CHARLIE A. HARRISON
ADRIENNE C. PUBLICOVER (SBN 161432)
DENNIS J. RHODES (SBN 168417)
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
Attorneys for Plaintiff
RELIANCE STANDARD LIFE INSURANCE COMPANY
MICHAEL COGAN, ESQ.
GENE TUCKER, ESQ.
Attorney for Defendant CHARLIE A. HARRISON
STIPULATION OF THE PARTIES FOR AN ORDER EXTENDING THE TIME TO
FILE DISPOSITIONAL DOCUMENT AND FOR A STATUS CONFERENCE
AND [PROPOSED] ORDER THEREON (L.R. 143)
Judge : Hon. Garland E. Burrell, Jr.
The parties, Plaintiff Reliance Standard Life Insurance Company ("Reliance Standard"), and Defendant Charlie Harrison ("Defendant"), by and through their attorneys of record hereby file this stipulation to extend the time for the filing of a dispositional document pursuant to this Court's Order dated September 1, 2011, for good cause as follows.
The parties are in the process of finalizing the settlement reached in this action and need additional time to perfect said settlement. Counsel for Reliance Standard has prepared the settlement agreement and said draft is currently being reviewed by Reliance Standard. Counsel are awaiting final changes by Reliance Standard.
Additional time is needed to complete the settlement in that counsel for Defendant is leaving the Country on September 14, 2011 and will not return until the end of September. Prior to leaving the country, counsel for Defendant will not have time to review the draft settlement agreement in detail and meet with Defendant. Therefore, he must wait until his return to do so. In addition, counsel for Reliance Standard is awaiting Reliance Standard's final approval of certain of the terms in the draft settlement agreement which may not be received in advance of September 9, 2011.
The parties fully expect they will be able to perfect the settlement no later than October 14, 2011. This will allow counsel for Reliance Standard to receive approval of the additional terms and counsel for Defendant to attend to his work load in a timely manner following his absence. Therefore, the parties respectfully request that the Court continue the date for the filing of a dispositional document from September 9, 2011 to October 14, 2011. The parties further request that the status conference currently set for October 3, 2011, be continued to October 31, 2011, or to a date that best accommodates this Court's docket. RESPECTFULLY SUBMITTED:
Date: September 7, 2011
WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP
By: Dennis J. Rhodes
ADRIENNE C. PUBLICOVER
DENNIS J. RHODES
Attorneys for Plaintiff
RELIANCE STANDARD LIFE INSURANCE COMPANY
LAW OFFICES OF MICHAEL COGAN
By: Michael Cogan
MICHAEL COGAN
GENE TUCKER
Attorneys for Defendant
CHARLIE HARRISON
ORDER
Pursuant to the Stipulation of the Parties herein, it is ordered that the date for filing a dispositional document is continued from September 9, 2011 to October 14, 2011. A status conference is set for October 31, 2011 at 9:00 a.m. A joint status report shall be filed fourteen days prior to the hearing.
GARLAND E. BURRELL, JR.
United States District Judge