Filed: Oct. 17, 2016
Latest Update: Oct. 17, 2016
Summary: STIPULATION AND ORDER TO EXTEND DEADLINES CARL W. HOFFMAN , District Judge . IT IS HEREBY STIPULATED by the parties hereto, by and through their undersigned counsel of record that, pursuant to LR 26-4, the Scheduling Order (Doc. # 20) be amended as follows: I. Discovery Completed Defendant HARTFORD LIFE AND ACCIDENT INSURANCE CO. (HARTFORD) produced its ERISA Administrative Record (AR) to Plaintiff for her review on September 1, 2016. Defendant UNIVERSAL HEALTH SERVICES, INC. (UHS) produ
Summary: STIPULATION AND ORDER TO EXTEND DEADLINES CARL W. HOFFMAN , District Judge . IT IS HEREBY STIPULATED by the parties hereto, by and through their undersigned counsel of record that, pursuant to LR 26-4, the Scheduling Order (Doc. # 20) be amended as follows: I. Discovery Completed Defendant HARTFORD LIFE AND ACCIDENT INSURANCE CO. (HARTFORD) produced its ERISA Administrative Record (AR) to Plaintiff for her review on September 1, 2016. Defendant UNIVERSAL HEALTH SERVICES, INC. (UHS) produc..
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STIPULATION AND ORDER TO EXTEND DEADLINES
CARL W. HOFFMAN, District Judge.
IT IS HEREBY STIPULATED by the parties hereto, by and through their undersigned counsel of record that, pursuant to LR 26-4, the Scheduling Order (Doc. # 20) be amended as follows:
I. Discovery Completed
Defendant HARTFORD LIFE AND ACCIDENT INSURANCE CO. (HARTFORD) produced its ERISA Administrative Record (AR) to Plaintiff for her review on September 1, 2016. Defendant UNIVERSAL HEALTH SERVICES, INC. (UHS) produced relevant documents to Plaintiff on September 14, 2016. Plaintiff CORBOSIERO notified UHS as to her position regarding permissible ERISA discovery on September 30, 2016.
The mediation between Plaintiff and HARTFORD scheduled for October 11, 2016 did not take place because Plaintiff was affected by Hurricane Matthew and was unable to travel to Las Vegas in time for the mediation. The mediation has now been rescheduled for January 24, 2017 with the same mediator, Honorable Lawrence Leavitt (Ret.). This was the earliest possible date that all parties and the mediator were available for the mediation.
II. Discovery Remaining and Reason for Request for Extension
The current upcoming deadline for Plaintiff CORBOSIERO to notify Defendant HARTFORD as to the content of Hartford's AR and any ERISA discovery is October 25, 2016. In the interest of judicial economy, Plaintiff CORBOSIERO and Defendant HARTFORD propose that all remaining deadlines between them be extended beyond the January 24, 2017 mediation to allow for possible settlement.
Plaintiff's dispositive motion regarding her second cause of action against Defendant UHS is currently due by November 4, 2016. Plaintiff and UHS are currently attempting to resolve this claim and therefore propose that all briefing deadlines be extended 30 days.
III. Proposed Discovery Schedule
A. Plaintiff's first cause of action against Hartford:
Plaintiff CORBOSIERO and Defendant HARTFORD propose the following deadline extensions regarding Plaintiff's First Cause of Action against Defendant HARTFORD (Doc #20, ¶¶ III.A through III.D):
Description: Current Deadline: Proposed:
Plaintiff to notify Defendant Hartford 10/25/16 01/27/17
as to the content of AR and any additional
discovery
Deadline to serve discovery that the 11/22/16 02/24/17
parties agree is permissible
Filing of Simultaneous Discovery 12/02/16 03/10/17
Motions
Plaintiff's Dispositive ERISA Motion 12/16/16 03/24/17
under Rule 52 and/or 56
Hartford's Opposition to Dispositive 01/20/17 04/21/17
Motion
Plaintiff's Reply 02/03/17 05/05/17
B. Plaintiff's second cause of action against UHS:
Plaintiff CORBOSIERO and Defendant UHS propose a 30-day extension of their remaining deadlines (Doc #20, ¶ IV.D):
Description: Current Deadline: Proposed:
Plaintiff's Dispositive Motion under 11/04/16 12/02/16
Rule 52 and/or 56
UHS's opposition to Dispositive 12/09/16 01/09/17
Motion
Plaintiff's Reply 12/30/16 01/30/17
We, the undersigned, represent to the Court that this request for extension is made in good faith and not for purposes of delay.
WHEREFORE, the parties jointly request that this Court adopt the proposed scheduling as indicated above.
IT IS SO ORDERED.
