REED

S

MIT

H LLP

A limited liability partnership formed in the State of Delaware

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No.: CIV. S-04-1684 DFL KJM – 1 – DOCSOAK-9772186.1-LOLIVER 

STIPULATION AND [PROPOSED] ORDER CONTINUING DATES SET IN STATUS (PRE-TRIAL 

SCHEDULING) ORDER 

James H. Fleming (SBN 042226) 

Linda B. Oliver (SBN 166720) 

REED SMITH LLP

1999 Harrison Street, Suite 2400 

Oakland, CA 94612-3572 

Mailing Address:

P.O. Box 2084 

Oakland, CA 94604-2084 

Telephone: 510.763.2000 

Facsimile: 510.273.8832 

Attorneys for Defendant 

Massachusetts Mutual Life Insurance 

Company 

OK/HAV 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

JOHN C. ROBINSON, 

Plaintiff, 

vs. 

MASSACHUSETTS MUTUAL LIFE 

INSURANCE COMPANY, SUCCESSOR IN 

INTEREST TO CONNECTICUT MUTUAL 

LIFE INSURANCE COMPANY, and DOES 1 

through 20, inclusive, 

Defendants. 

No.: CIV. S-04-1684 DFL KJM 

STIPULATION AND [PROPOSED] 

ORDER CONTINUING DATES SET IN 

STATUS (PRE-TRIAL SCHEDULING) 

ORDER 

IT IS HEREBY STIPULATED by and between the parties hereto, through their 

respective attorneys of record, as follows: 

1. The Court’s Status (Pre-trial Scheduling) Order dated October 25, 2004, set 

the following dates: 

a. Discovery cut-off date: April 29, 2005; 

b. Last day to file dispositive motions: June 1, 2005; 

c. Hearing on dispositive motions: July 13, 2005, 10:00 a.m.; 

d. Final pre-trial conference: August 26, 2005, 3:00 p.m., with joint pretrial 

statement due no later than seven days before the conference; and 

Case 2:04-cv-01684-DFL -KJM Document 22 Filed 05/04/05 Page 1 of 2
REED

S

MIT

H LLP

A limited liability partnership formed in the State of Delaware

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No.: CIV. S-04-1684 DFL KJM – 2 – DOCSOAK-9772186.1-LOLIVER 

STIPULATION AND [PROPOSED] ORDER CONTINUING DATES SET IN STATUS (PRE-TRIAL 

SCHEDULING) ORDER 

e. Trial date: October 3, 2005, 9:00 a.m. 

2. The parties respectfully request that the Court issue an order extending these 

deadlines so the parties have time to complete a mediation before incurring the expense of 

completing all fact and expert discovery, as follows: 

a. Discovery cut-off date: July 28, 2005; 

b. Last day to file dispositive motions: September 7, 2005; 

c. Hearing on dispositive motions: October 5, 2005, 10:00 a.m.; 

d. Final pre-trial conference: November 16, 2005, 4:00 p.m., with joint 

pretrial statement due no later than seven days before the conference; and 

e. Trial date: December 12, 2005, 9:00 a.m. 

3. The parties have not made any previous request for an extension of 

time for these dates. 

DATED: May 2, 2005 

 REED SMITH LLP

By //s// 

Linda B. Oliver 

Attorneys for Defendant Massachusetts Mutual 

Life Insurance Company 

DATED: May 2, 2005 

 LAW OFFICE OF JOHN M. RIESTENBERG 

By //s// 

John M. Riestenberg 

Attorneys for Plaintiff John C. Robinson 

IT IS SO ORDERED. 

Dated: 5/3/2005 

/s/ David F. Levi 

DAVID F. LEVI 

United States District Judge 

Case 2:04-cv-01684-DFL -KJM Document 22 Filed 05/04/05 Page 2 of 2