STIPULATION FOR TWO-WEEK CONTINUANCE FOR REMAINING BRIEFING FOR CROSS —MOTION FOR JUDGMENT AND HEARING DATE; [PROPOSED] ORDER

JON S. TIGAR, District Judge.

For the reasons set forth below, the parties respectfully request that the Court permit a continuance of the following briefing schedule deadline and corresponding

By and through their counsel of record, Plaintiff Hadar Meiri ("Meiri") and Defendant Hartford Life and Accident Insurance Company ("Hartford"), hereby stipulate and respectfully request that the Court permit a two-week continuance of the remaining briefing schedule deadlines with a corresponding change in the hearing date. Good cause exists as follows:

Whereas in this ERISA case, the Court set a briefing schedule for the parties' respective Cross-motions for Judgment under FRCP Rule 52. (Doc. 19) Plaintiff Meiri filed her Motion for Judgment on October 19, 2016. Defendant Hartford filed its Motion for Judgment on November 9, 2016.

Whereas the parties requested a continuance of the responsive motion deadlines and trial due to the medical leave and rehabilitation of Plaintiff's counsel, Rebecca Grey, in late October, as well as limited availability of legal staff and conflicts from winter holidays. The Court set the following dates: Plaintiff's responsive brief extended from November 30, 3016 to January 5, 2017; Defendant's responsive brief extended from December 21, 2016 to February 2, 2017; and the Motion hearing moved from January 12, 2017 to February 16, 2017, at 2:00 p.m.

Since that time, in late November, Defendant's counsel, Melissa M. Cowan, had a trial set for January 30, 2016, in the United States District Court, Northern District of California, in Arlene Tom v. Hartford Life and Accident Insurance Company, Case No. 16-cv-01067. The pre-trial conference in that case is set for January 18, 2017, and the district court has already confirmed trial will proceed as scheduled. Ms. Cowan is the only attorney handling the Meiri case, such that the January 30th trial will affect her ability to prepare and complete Hartford's responsive brief which is due that same week. Ms. Cowan's husband is also scheduled for surgery on January 25, 2017, and it cannot be moved.

Plaintiff filed her responsive brief on January 5, 2017, which included a motion to strike a prior declaration filed by Defendant's counsel. The parties met and conferred and propose the following new schedule to accommodate these unavoidable issues.

IT IS SO STIPULATED

PURSUANT TO STIPULATION, IT IS SO ORDERED.