Whelan-Vanderhorst v. Metropolitan Life Insurance Company

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STIPULATION RE PLAINTIFF’S MOTION FOR
REMAND
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ROBERT HESS (SBN 178042)
RHess@maynardnexsen.com
MAYNARD NEXSEN LLP
10100 Santa Monica Boulevard, Suite 550
Los Angeles, CA 90067
Telephone: 310.596.4500
Attorneys for Defendant
Metropolitan Life Insurance Company
UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
JOAN WHELAN-VANDERHORST
Plaintiff,
v.
METROPOLITAN LIFE INSURANCE
COMPANY and Does 1 through 30, inclusive
Defendant.
Case No. 1:25-cv-01664 KES-SKO
STIPULATION RE PLAINTIFF’S
MOTION TO REMAND; ORDER
Complaint Filed: October 14, 2025
Case 1:25-cv-01664-KES-SKO Document 11 Filed 01/13/26 Page 1 of 3

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STIPULATION RE PLAINTIFF’S MOTION FOR
REMAND
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TO THE HONORABLE KIRK E. SHERRIFF AND HIS COURT CLERK:
Plaintiff Joan Whelan-Vanderhorst (“Plaintiff”) and Defendant Metropolitan Life
Insurance Company (“Defendant”), by and through their respective counsel, hereby stipulate to
further continue the remaining briefing and hearing dates relating to Plaintiff’s recently filed
Motion to Remand Action to State Court (Dkt No. 5 and 5-1).
This Court previously approved the parties’ request to continue Defendant’s remand
opposition deadline by one week. (Dkt No. 9) Since then, the parties have focused their efforts on
confirming the value of the potential damages in this case and reaching an informal settlement,
and the parties are optimistic that a settlement will be reached in the very near future.
In light of the foregoing, and in order to avoid unnecessarily burdening the Court’s
resources and to allow the parties to focus their efforts on settlement, the parties jointly request
that the remaining briefing and hearing dates relating to Plaintiff’s Motion to Remand be continued
to the dates set forth below:
- Defendant’s deadline for filing an opposition to the Remand Motion shall be
continued from January 13, 2026 to February 3, 2026;
- Plaintiff’s deadline for filing a reply brief shall be continued from January 20,
2026 to February 10, 2026;
- The hearing on the motion shall be continued from February 9, 2026 to
February 23, 2026 at 1:30 p.m.
IT IS SO STIPULATED.
DATED: January 13, 2026
By:
MAYNARD NEXSEN LLP
/s/ Robert Hess
ROBERT HESS
Attorneys for Defendant
Metropolitan Life Insurance Company
DATED: January 13, 2026
By:
WHELAN LAW GROUP
/s/ Brian D. Whelan
BRIAN D. WHELAN
Attorneys for Plaintiff
Joan Whelan-Vanderhorst
Case 1:25-cv-01664-KES-SKO Document 11 Filed 01/13/26 Page 2 of 3

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ORDER
Pursuant to the Stipulation of the parties and for good cause shown, the Court hereby
revises the following briefing schedule for plaintiff’s Motion to Remand as follows:
- Defendant’s opposition to the Motion to Remand shall be due on or before
February 3, 2026;
- Plaintiff’s reply brief shall be due on or before February 10, 2026;
- The hearing on the Motion is scheduled for February 23, 2026 at 1:30 p.m.
IT IS SO ORDERED.
Dated: January 13, 2026
UNITED STATES DISTRICT JUDGE
Case 1:25-cv-01664-KES-SKO Document 11 Filed 01/13/26 Page 3 of 3