Free Order - District Court of California - California

Case 3:07-cv-04870-PJH

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Filed 12/10/2007

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SEAN P. NALTY (SBN 121253) WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP 525 Market Street, 17th Floor San Francisco, California 94105 Telephone: (415) 433-0990 Facsimile: (415) 434-1370 Attorneys for Defendant THE PERMANENTE MEDICAL GROUP LONG TERM DISABILITY PLAN

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

LAWRENCE SIROTT, Plaintiff, vs. THE PERMANENTE MEDICAL GROUP LONG TERM DISABILITY PLAN, Defendant.

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Case No.: C 07-04870 PJH JOINT STIPULATION AND REQUEST FOR A CONTINUANCE OF THE CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER

The parties in the above-captioned matter, Lawrence Sirott, M.D., through his counsel of record, Daniel Feinberg, Lewis, Feinberg, Lee, Renaker & Jackson, P.C., and defendant The Kaiser Permanente Medical Group Long Term Disability Plan, through its counsel of record, Sean P. Nalty, Wilson, Elser, Moskowitz, Edelman & Dicker, hereby jointly request a one-month continuance of the Case Management Conference in this matter and the dates associated with the Conference. Currently, December 13, 2007 is the last day to meet and confer concerning ADR options. December 27, 2007 is the last day to file a Rule 26(f) report, complete Rule 26 disclosures, and file a Case Management Conference Statement. The initial Case Management Conference in this matter is set for January 3, 2008.

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USDC NDCA Case #C 07-04870 PJH

Case 3:07-cv-04870-PJH

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Filed 12/10/2007

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The parties request this continuance because they are trying to settle this matter and believe that this can be done with additional time. The parties agree that it is important to these settlement efforts that the parties minimize incurring additional legal fees. Accordingly, based on the explanation above, the parties hereby stipulate that the Case Management Conference in this matter, and the various dates associated with the conference, may be continued for 30 days. IT IS SO STIPULATED. Dated: December 7, 2007 WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP By: /s/ SEAN P. NALTY Attorneys for Defendant THE PERMANENTE MEDICAL GROUP LONG TERM DISABILITY PLAN

Dated: December 7, 2007

LEWIS, FEINBERG, LEE, RENAKER & JACKSON

By_____________/s/_________________________ DANIEL FEINBERG Attorneys for Plaintiff LAWRENCE SIROTT

Based on the stipulation of the parties, and good cause appearing therefore, the Court will is continued issue a new initial scheduling order continuing the Case Management Conference in this matter for 30 days as well as the dates leading up to the Conference. Case Management Conference is set for 2/7/08 at 2:30 p.m. IT IS SO ORDERED. Dated: 12/10/07
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