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Santos v. Quebecor World Long Term Disability Plan

August 27, 2008

GUADALUPE SANTOS, PLAINTIFF,
v.
QUEBECOR WORLD LONG TERM DISABILITY PLAN, DEFENDANT



The opinion of the court was delivered by: Honorable Gary S. Austin

STIPULATION & ORDER TO MODIFY SCHEDULING ORDER/SET VOLUNTARY SETTLEMENT CONFERENCE

Plaintiff, Guadalupe Santos, and Defendant, Quebecor World Long Term Disability Plan, through counsel, hereby stipulate as follows:

1. Good cause exists to modify the Scheduling Conference Order filed on July 24, 2008 in this case. Specifically, the parties desire to engage in settlement negotiations and a voluntary settlement conference and do not wish to incur the expense and time consumption of discovery motions and discovery prior to such settlement negotiations.

2. Therefore, the parties stipulate that the Scheduling Conference Order be modified as follows:

A. To extend the deadline for Defendant to file a counterclaim from August 29, 2008 to September 29, 2008.

B. To set a voluntary settlement conference on a date convenient for the Court and the parties, but on or before October 3, 2008.

C. To modify the Order regarding the Scheduling Conference and setting Further Scheduling Conference filed July 24, 2008, as follows:

(1) Plaintiff shall file a motion for leave to conduct discovery on or before October 10, 2008.

(2) Defendant shall file its opposition and motion, if any, on or before October 24, 2008.

(3) Plaintiff shall file her reply, if any, on or before October 31, 2008.

(4) The hearing on such motion shall be noticed for Friday, November 14, 2008 at 9:30 a.m., in Courtroom 10 before the Honorable Gary S. Austin.

(5) The Court shall set the matter for a further Scheduling Conference on November 20, 2008 at 9:30 a.m., before the Honorable Gary S. Austin. The parties shall submit a Joint Scheduling Report to the Court on or before November 13, 2008. The parties may appear for the conference telephonically by arranging a conference call and confirming their telephonic appearance with the courtroom deputy no later than two court days before the further Scheduling Conference.

THE ERISA LAW GROUP

Dated: August ...


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