Free Stipulation - District Court of California - California

Case 4:07-cv-05044-CW

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Filed 12/21/2007

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1 Michele Ballard Miller (SBN 104198) Lisa C. Hamasaki (SBN 197628) 2 Katherine L. Kettler (SBN 231586) MILLER LAW GROUP 3 A Professional Corporation 60 E. Sir Francis Drake Blvd., Ste. 302 4 Larkspur, CA 94939 Tel. (415) 464-4300 5 Fax (415) 464-4336 6 Attorneys for Defendant SBC ADVANCED SOLUTIONS, INC., a Delaware Corporation 7 And SEDGWICK CLAIMS MANAGEMENT SERVICES, INC., an Illinois Corporation 8 John H. Aspelin (SBN 56477) 9 ASPELIN & BRIDGMAN, LLP 220 Montgomery Street, Suite 1009 10 San Francisco, CA 94104 Tel. (415) 296-9812 11 Fax (415) 296-9814 12 Attorneys for Plaintiff CATHE GUERRA 13
A P R OF E SS I ON AL C O RP OR A T IO N L A R KSP UR , C AL IF OR NI A

M ILLER L AW G ROUP

14 15 16 17 CATHE GUERRA, 18 19 20 v. 21 Plaintiff,

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION Case No.: C 07-5044 CW STIPULATED REQUEST TO CONTINUE THE JANUARY 8, 2008 INITIAL CASE MANAGEMENT CONFERENCE AND ASSOCIATED DATES AND [PROPOSED] ORDER

SBC ADVANCED SOLUTIONS, INC., a 22 Delaware Corporation; SEDGWICK CLAIMS MANAGEMENT SERVICES, INC., An Illinois 23 Corporation; and PLAN TRUSTEE; 24 Defendants. 25 26 27 28
STIPULATED REQUEST TO CONTINUE THE JANUARY 8,2008 INITIAL CASE MANAGEMENT CONFERENCE AND ASSOCIATED DATES AND [PROPOSED] ORDER Case No. C 07-5044 CW

Case 4:07-cv-05044-CW

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The Parties, Plaintiff CATHE GUERRA (hereinafter "Plaintiff") and Defendants

2 SBC ADVANCED SOLUTIONS, INC., a Delaware Corporation; and SEDGWICK CLAIMS 3 MANAGEMENT SERVICES, INC., An Illinois Corporation (hereinafter jointly "Defendants"), 4 by and through their undersigned attorneys, hereby stipulate to continue the Initial Case 5 Management Conference currently calendared for January 8, 2008 at 2:00 p.m. to February 6 12, 2008 at 2:00 p.m. Parties further agree to continue all associated deadlines, including 7 applicable ADR deadlines, the deadline for completing initial disclosures, filing a case 8 management statement and filing a Rule 26(f) report to the dates set forth below: 9 10 11 12 13
A P R OF E SS I ON AL C O RP OR A T IO N L A R KSP UR , C AL IF OR NI A

January 22, 2008

M ILLER L AW G ROUP

14 15 16 17 18 19 20 February 12, 2008 February 5, 2008

Last day to: · Meet and confer re: initial disclosures, early settlement, ADR process selection and discovery plan; · File ADR Certification signed by Parties and Counsel; · File either Stipulation to ADR Process or Notice of Need for ADR Phone Conference. Last day to complete initial disclosures or state objection in Rule 26(f) Report, file Case Management Statement, and file Rule 26(f) Report INITIAL CASE MANAGEMENT CONFERENCE

Good cause exists for this extension because the parties continue to negotiate

21 over the identity of the proper defendant in this case, that will likely result in Plaintiff filing an 22 amended complaint. 23 24 25 26 27 28
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STIPULATED REQUEST TO CONTINUE THE JANUARY 8, 2008 INITIAL CASE MANAGEMENT CONFERENCE AND ASSOCIATED DATES AND [PROPOSED] ORDER; Case No. C 07-5044 CW

Case 4:07-cv-05044-CW

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Accordingly, it is in the interest of the parties to await the outcome of that

2 negotiation before proceeding with ADR discussions, or expending time and resources on 3 preparing initial disclosures, a Rule 26(f) report or an initial case management conference. 4 5 6 7 Dated: December 21, 2007 8 9 10 11 12 Dated: December 21, 2007 13
A P R OF E SS I ON AL C O RP OR A T IO N L A R KSP UR , C AL IF OR NI A

IT IS SO STIPULATED.

ASPELIN & BRIDGMAN, LLP

By:

/S/ John H. Aspelin Attorneys for Plaintiff CATHE GUERRA

MILLER LAW GROUP A Professional Corporation

M ILLER L AW G ROUP

14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
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STIPULATED REQUEST TO CONTINUE THE JANUARY 8, 2008 INITIAL CASE MANAGEMENT CONFERENCE AND ASSOCIATED DATES AND [PROPOSED] ORDER; Case No. C 07-5044 CW

By: /S/ Katherine L. Kettler Attorneys for Defendant SBC ADVANCED SOLUTIONS, INC., a Delaware Corporation and SEDGWICK CLAIMS MANAGEMENT SERVICES INC., An Illinois Corporation

Case 4:07-cv-05044-CW

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ORDER

Having reviewed the Stipulation executed by Plaintiff CATHE GUERRA and

4 Defendants SBC ADVANCED SOLUTIONS, INC., a Delaware Corporation; and 5 SEDGWICK CLAIMS MANAGEMENT SERVICES, INC., an Illinois Corporation, and good 6 cause appearing, the Court hereby orders that the January 8, 2008 Initial Case 7 Management Conference and associated dates are vacated and rescheduled pursuant to 8 the schedule set forth below. 9 10 11 12 13
A P R OF E SS I ON AL C O RP OR A T IO N L A R KSP UR , C AL IF OR NI A

January 8, 2008

M ILLER L AW G ROUP

14 15 16 17 18 19 20 21 22 Dated: ________________________ 23 24 25 26 27 28 IT IS SO ORDERED. ______________ ______________

Last day to: · Meet and confer re: initial disclosures, early settlement, ADR process selection and discovery plan · File ADR Certification signed by Parties and Counsel · File either Stipulation to ADR Process or Notice of Need for ADR Phone Conference Last day to complete initial disclosures or state objection in Rule 26(f) Report, file Case Management Statement, and file Rule 26(f) Report INITIAL CASE MANAGEMENT CONFERENCE

_______________________________ The Honorable Claudia Wilken United States District Judge

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STIPULATED REQUEST TO CONTINUE THE JANUARY 8, 2008 INITIAL CASE MANAGEMENT CONFERENCE AND ASSOCIATED DATES AND [PROPOSED] ORDER; Case No. C 07-5044 CW