ADRIENNE C. PUBLICOVER (SBN 161432) Email: firstname.lastname@example.org DENNIS J. RHODES (SBN 168417) Email: email@example.com WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP 525 Market Street, 17th Floor San Francisco, California 94105 Tel: (415) 433-0990 Fax: (415) 434-1370 Attorneys for Defendant PRINCIPAL LIFE INSURANCE COMPANY JESSICA LYNN MATTAVI (SBN 254631) Email: firstname.lastname@example.org STEPHENSON, ACQUISTO & COLMAN 303 North Glenoaks Blvd., Suite 700 Burbank, California 91502 Tel: 818-559-4477 Fax: 818-559-5484 Attorneys for PLAINTIFF ENLOE MEDICAL CENTER
State Action Filed: June 11, 2010
THE PARTIES JOINT STIPULATION TO CONTINUE THE MOTION HEARING CUT OFF DATE BY THIRTY (30) DAYS FOR GOOD CAUSE PRINCIPAL TO THE COURT AND ALL PARTIES AND THEIR COUNSEL OF RECORD:
The last date for hearing on the parties' dispositive motions is currently set by this Court for July 8, 2011 in the above captioned matter. This matter is currently set for Trial beginning November 7, 2011.
All parties and their attorneys of record hereby agree and stipulate to continue the cut off date for hearing of the parties' dispositive motions and related deadlines by thirty (30) days and request the 7 court grant this thirty (30) day continuance to August 7, 2011.
There have been no prior requested continuances regarding this deadline and related deadlines.
Furthermore, good cause exists for the continuance of this hearing and its related deadlines for the following reasons:
Due to the availability of hearing days on the Court's motion calendar and the need to provide proper notice of a motion for summary judgment, the parties agree that it is necessary to continue the dispositive motion deadline and related deadlines by thirty (30) days.
The thirty day continuance is requested in good faith and not to delay the proceedings in this matter. The trial date in this matter is not affected by the requested extension.
THE FOREGOING IS SO STIPULATED:
Good cause appearing therefore, the Court hereby orders that the Hearing Cut Off Date on the parties' dispositive motions is continued to August 7, 2011.
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