Opinion
R. Craig Clark, James M. Treglio, CLARK & TREGLIO, San Diego, CA, David Markham, THE MARKHAM LAW FIRM, San Diego, CA, Walter Haines, UNITED EMPLOYEES LAW GROUP, Huntington Beach, CA, Attorneys for Plaintiff and the Putative Class.
MANATT, PHELPS & PHILLIPS, LLP, Sharon B. Bauman, Christopher A. Rheinheimer, Sunny Hwang, Attorneys for Defendant.
STIPULATION TO EXTEND TIME FOR PLAINTIFF TO RESPOND TO DEFENDANT'S MOTION FOR PARTIAL SUMMARY JUDGMENT
EDWARD M. CHEN, District Judge.
Plaintiff Ronnie Richie and Defendant Blue Shield of California (collectively "the Parties") hereby stipulate to extend the time for Plaintiff to respond to Defendant's Motion for Partial Summary Judgment:
WHEREAS, Defendant filed a Motion for Partial Summary Judgment on August 13, 2013, thereby making Plaintiff's opposition to Defendant's Motion due on August 27, 2015 and Defendant's reply to Plaintiff's opposition due on September 3, 2015;
WHEREAS, on August 18, 2015, the Parties engaged in a mediation before well respected mediator David Rotman, Esq., of Gregorio, Haldeman, & Rotman;
WHEREAS, the mediation ended with a mediators proposal, with a response being due on August 26, 2015;
WHEREAS, to allow the Parties time to communicate with their clients and to consider the mediator's proposal, the Parties have agreed to extend the due date for Plaintiff's opposition to Defendant's Motion from August 27, 2015 to September 15, 2015.
NOW THEREFORE, THE PARTIES AGREE AND STIPULATE THAT:
1. The hearing date for Defendant's Motion for Partial Summary Judgment is continued to October 15, 2015;
2. The deadline for Plaintiff to file an opposition to Defendant's Motion is September 15, 2015; and
3. The deadline for Defendant to file a reply to Plaintiff's opposition is September 24, 2015.
[PROPOSED] ORDER
PURSUANT TO PARTIES STIPULATION AND GOOD CAUSE APPEARING, IT IS HEREBY ORDERED that:
1. The hearing date for Defendant's Motion for Partial Summary Judgment is continued to October 15, 2015;
2. The deadline for Plaintiff to file an opposition to Defendant's Motion is September 15, 2015; and
3. The deadline for Defendant to file a reply to Plaintiff's opposition is September 24, 2015.