Filed: Feb. 01, 2019
Latest Update: Feb. 01, 2019
Summary: STIPULATION TO EXTEND MEDIATION DEADLINE AND ALL OTHER DISCOVERY AND BRIEFING DATES; [PROPOSED] ORDER GEORGE FOLEY, JR. , Magistrate Judge . STIPULATION TO EXTEND MEDIATION DEADLINE AND ALL OTHER RELEVANT DATES; [PROPOSED] ORDER UNUM LIFE INSURANCE COMPANY OF AMERICA ("Unum Life"), and ROSEANNE BUSEY ("Plaintiff"), (collectively referred to herein as the "parties"), by and through their respective counsel of record, hereby stipulate and request the Court's agreement to extend the current
Summary: STIPULATION TO EXTEND MEDIATION DEADLINE AND ALL OTHER DISCOVERY AND BRIEFING DATES; [PROPOSED] ORDER GEORGE FOLEY, JR. , Magistrate Judge . STIPULATION TO EXTEND MEDIATION DEADLINE AND ALL OTHER RELEVANT DATES; [PROPOSED] ORDER UNUM LIFE INSURANCE COMPANY OF AMERICA ("Unum Life"), and ROSEANNE BUSEY ("Plaintiff"), (collectively referred to herein as the "parties"), by and through their respective counsel of record, hereby stipulate and request the Court's agreement to extend the current m..
More
STIPULATION TO EXTEND MEDIATION DEADLINE AND ALL OTHER DISCOVERY AND BRIEFING DATES; [PROPOSED] ORDER
GEORGE FOLEY, JR., Magistrate Judge.
STIPULATION TO EXTEND MEDIATION DEADLINE AND ALL OTHER RELEVANT DATES; [PROPOSED] ORDER
UNUM LIFE INSURANCE COMPANY OF AMERICA ("Unum Life"), and ROSEANNE BUSEY ("Plaintiff"), (collectively referred to herein as the "parties"), by and through their respective counsel of record, hereby stipulate and request the Court's agreement to extend the current mediation deadline and all other relevant discovery and briefing dates by an additional 45 days.
On January 10, 2019, the parties jointly filed a Proposed Discovery Plan and Proposed Scheduling Order proposing the last day to complete mediation be March 1, 2019. (Doc No. 12). The Court affirmed that deadline in its Scheduling Order (Doc No. 13);
The parties have agreed to mediate with a private mediator who is experienced under the Employee Retirement Income Security Act of 1974.
The parties agreed to mediate with Adrienne Publicover of JAMS.
Given the schedules of the attorneys, the parties and the mediator, the earliest dates on which mediation may take place is March 25, 26 or 27, 2019, in Reno, Nevada.
For good cause, the Parties wish to continue the Mediation deadline from March 1, 2019 to April 15, 2019 (45 days) to ensure compliance.
The Parties further agree they wish to continue all other discovery and briefing dates to avoid unnecessary litigation costs and to ensure there is no prejudice to either Party due to the extended mediation date.
Below is a table indicating the existing deadlines and the proposed new deadlines.
Event Existing Date Proposed New Date
Last date to complete mediation March 1, 2019 April 15, 2019
Last date to File Cross Briefs March 18, 2019 May 2, 2019
Regarding Allowance of Expert
Discovery
Last date for Defendant's Filing June 21, 2019 August 5, 2019
of Administrative Record
Last date to file Opening Briefs July 12, 2019 August 26, 2019
Last date to file Opposition August 2, 2019 September 16, 2019
Briefs
Oral Hearing/Trial Date August 16, 2019 September 27, 2019
The Parties respectfully request that the Court grant the proposed continuation of the mediation deadline and all other dates for the reasons stated. The Parties certify that there have been no prior time modifications for deadlines in this case, and do not believe that this extension sought to continue the mediation deadline and all other dates will prejudice any party or result in undue delay.
IT IS SO STIPULATED.
AFFIRMATION
The undersigned does hereby affirm that the preceding document does not contain the social security numbers of any person. Additionally, the filing attorney attests that she has obtained concurrence regarding the filing of this document and its content from the signatories to this document.
IT IS SO ORDERED.
