Opinion
Case No.: CV 08 1575 MMC
10-24-2011
LOUIS J. VELA, Plaintiff, v. AT&T UMBRELLA BENEFIT PLAN NO. 1, Defendant.
GOLDSTEIN, GELLMAN, MELBOSTAD, HARRIS & MCSPARRAN, LLP Lee S. Harris Attorneys for Plaintiff LOUIS J. VELA MILLER LAW GROUP A Professional Corporation Katherine L. Kettler Attorneys for Defendant AT&T UMBRELLA BENEFIT PLAN NO. 1
Katherine L. Kettler (SBN 231586)
Jennifer A. Shy (SBN 131074)
MILLER LAW GROUP
A Professional Corporation
Attorneys for Defendant
AT&T UMBRELLA BENEFIT PLAN NO. 1
Lee S. Harris (SBN 076699)
GOLDSTEIN, GELLMAN, MELBOSTAD,
HARRIS & MCSPARRAN, LLP
Attorneys for Plaintiff
LOUIS J. VELA
STIPULATION AND [PROPOSED] ORDER
TO CONTINUE FILING DATES RELATED
TO PARTIES' MOTIONS FOR SUMMARY
JUDGMENT
Complaint filed: March 21, 2008
First Am. Complaint filed: May 14, 2008
Second Am. Complaint filed: Oct. 9, 2008
Plaintiff Louis Vela ("Plaintiff") and Defendant AT&T Umbrella Benefit Plan No. 1 ("Defendant") (collectively the "Parties"), by and through their respective counsel of record, hereby stipulate as follows:
The Parties previously stipulated to a briefing schedule in support of their respective Motions for Summary Judgment as reflected in the Court's Order filed on August 12, 2011 (Docket No. 86). Now, the Parties stipulate and respectfully request the Court to further continue the Parties' present deadline for re-noticing their respective Motions for Summary Judgment and for filing Further Briefing, from November 4, 2011 to December 5, 2011, and continue the Parties' present deadline for filing Responses to Further Briefing from November 18, 2011 to December 19, 2011. The Parties also request that the Court allow each Party up to ten (10) pages for their Responses to Further Briefing (instead of the five pages currently allowed.)
Good cause exists for the requested continuance of these filing dates, as the reopened deposition of Ms. Tonya Warner was taken on October 13, 2011, and the extension of time allows a reasonable time for the completion of the transcript, as well as the 30-day statutory review period set forth in the Federal Rules of Civil Procedure, Rule 30(e).
The Parties wish to further inform that Court that they have engaged, through their respective counsel, in discussion about the possibility of conducting further efforts to informally resolve this dispute. In the event that the Parties agree to such further efforts, the Parties may approach the Court to request a further continuance of the dates above related to the filing of the Parties' Motions for Summary Judgment.
IT IS SO STIPULATED.
GOLDSTEIN, GELLMAN, MELBOSTAD,
HARRIS & MCSPARRAN, LLP
Lee S. Harris
Attorneys for Plaintiff
LOUIS J. VELA
MILLER LAW GROUP
A Professional Corporation
Katherine L. Kettler
Attorneys for Defendant
AT&T UMBRELLA BENEFIT PLAN NO. 1
IT IS SO ORDERED
HONORABLE MAXINE M. CHESNEY