The opinion of the court was delivered by: Chief Judge Vaughn R. Walker
JOINT STIPULATION TO CONTINUE SCHEDULING CONFERENCE AND [PROPOSED] ORDER
Action filed: April 15, 2009
TO THE HONORABLE JUDGE OF THE COURT:
Plaintiff Ann Edwards and defendant Life Insurance Company of North America (hereinafter "LINA"), by and through their respective counsel of record, hereby stipulate and respectfully request that the Scheduling Conference currently scheduled for September 3, 2009 in this matter be continued for approximately 60 days. The parties have reached a settlement of this matter and are in the process of finalzing a release memorializing the terms of the parties' settlement.
In light of the parties' settlement, good cause exists to grant the parties' request for a continuance based on the following grounds:
1. The above-entitled action was filed on April 15, 2009 in this Court;
2. On or about April 22, 2009, LINA was served with the summons and complaint filed in this action;
2. On May 13, 2009, counsel for LINA filed a stipulation for continuance of time to May 26, 2009 to file a responsive pleading;
3. On May 26, 2009, counsel for LINA filed a second stipulation for continuance of time to June 9, 2009 to file a responsive pleading;
4. On June 9, 2009, LINA filed and served an answer to plaintiff's complaint;
5. On June 15, 2009, the Court rescheduled the date of the initial case management conference to September 3, 2009 at 3:30 p.m.
6. On or about July 29, 2009, the parties orally reached a settlement of all claims in this action. The parties are currently in the process of finalizing a release, which memorializes the terms of the settlement.
For all the stated reasons above, IT IS HEREBY STIPULATED AND AGREED by and between the parties and their respective counsel of record, and it is respectfully requested that the Court permit and enter an Order to continue the Initial Case Management Conference currently set for September 3, 2009 for an ...