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Hadley v. Prudential Insurance Company of America

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA-SACRAMENTO


December 1, 2009

JULIA HADLEY, PLAINTIFF
v.
THE PRUDENTIAL INSURANCE COMPANY OF AMERICA, A NEW JERSEY CORPORATION, AND DOES 1 THRU 50, INCLUSIVE. DEFENDANT(S).

STIPULATION AND PROPOSED ORDER FOR CONTINUANCE OF DISCOVERY AND MOTION HEARINGS

WHEREAS, the purpose of this Stipulation is for Continuance of Discovery and Motion Hearing to ensure that the parties have adequate time to perform all discovery and related motions necessary to prosecute and defend all claims as set forth in this cause of action; and

WHEREAS, the Status and Pretrial Scheduling Order dated May 28, 2009 requires that all discovery, including depositions for preservation of testimony, is left open, save and except that it shall be so conducted as to be completed by January 8, 2010.

WHEREAS, the Status Pretrial Scheduling Order dated May 28, 2009 requires that all motions, except motions for continuance, temporary restraining orders, or other emergency applications, shall be filed on or before February 9, 2010.

STIPULATION AND ORDER

IT IS HEREBY STIPULATED between Plaintiff, represented by and through counsel, and Defendants, represented by and through counsel, for a slight modification of the Pretrial Scheduling Order dated May 28, 2009 as follows:

1. Section IV is modified so that all discovery, including depositions for preservation of testimony, is left open, save and except that it shall be so conducted as to be completed by March 26, 2010.

2. Section V of the Pretrial Scheduling Order dated May 28, 2009 is modified so that all motions, except motions for continuance, temporary restraining order, or other emergency applications, shall be filed on or before April 7, 2010. Good cause exists for this request as the parties would like to attempt to resolve this matter before incurring the costs of significant discovery and are scheduling mediation before Judge Cecily Bond, Ret., on February 17, 2010.

The parties have diligently pursued discovery. Plaintiff has requested the depositions of at least six employees at Prudential and six employees at UC Davis. Due to the Holidays, and December is a particularly busy month for Prudential, and because of the costs, the parties have agreed to schedule the depositions after the mediation, which is after the current discovery cut-off date. ORDER

Pursuant to the Stipulation of Plaintiff Julia Hadley and Defendant The Prudential Insurance Company of America, and good cause appearing, an Order extending discovery to March 26, 2010 and Motion Hearings to April 7, 2010 is entered.

IT IS SO ORDERED.

20091201

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