Kersting v. UnitedHealth Group

CourtDistrict Court, S.D. California
DecidedMarch 3, 2023
Docket3:23-cv-00159
StatusUnknown

This text of Kersting v. UnitedHealth Group (Kersting v. UnitedHealth Group) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kersting v. UnitedHealth Group, (S.D. Cal. 2023).

Opinion

1 2 3 4 5 6 7 8 9 UNITED STATES DISTRICT COURT 10 SOUTHERN DISTRICT OF CALIFORNIA 11 12 TERESA KERSTING, Case No.: 3:23-cv-00159-TWR-AHG 13 Plaintiff, ORDER GRANTING IN PART JOINT MOTION TO CONTINUE 14 v. EARLY NEUTRAL EVALUATION 15 UNITEDHEALTH GROUP, CONFERENCE AND CASE MANAGEMENT CONFERENCE 16 Defendant.

17 [ECF No. 6] 18 19 Before the Court is the parties’ joint motion to continue the Early Neutral Evaluation 20 Conference (“ENE”) and Case Management Conference (“CMC”), currently scheduled for 21 March 9, 2023. ECF No. 6. 22 Parties seeking to continue an ENE must demonstrate good cause. ECF No. 4 at 6 23 (“An ENE may be rescheduled only upon a showing of good cause”); Chmb.R. at 2 (stating 24 that any request for continuance requires “[a] showing of good cause for the request”); see, 25 e.g., FED. R. CIV. P. 6(b) (“When an act may or must be done within a specified time, the 26 court may, for good cause, extend the time”). 27 “Good cause” is a non-rigorous standard that has been construed broadly across 28 procedural and statutory contexts. Ahanchian v. Xenon Pictures, Inc., 624 F.3d 1253, 1259 1 (9th Cir. 2010). The good cause standard focuses on the diligence of the party seeking to 2 amend the scheduling order and the reasons for seeking modification. Johnson v. Mammoth 3 Recreations, Inc., 975 F.2d 604, 609 (9th Cir. 1992) (“[T]he focus of the inquiry is upon 4 the moving party’s reasons for seeking modification. . . . If that party was not diligent, the 5 inquiry should end.”) (internal citation omitted). 6 Here, the parties have represented to the Court that Defendant’s client representative 7 is unavailable to attend the ENE. ECF No. 6 at 2. Therefore, the parties seek a continuance 8 of the ENE, CMC, and related deadlines. Id. The parties identified March 20, 21, or 23 as 9 mutually agreeable conference dates. Id. at 3. 10 As an initial matter, the parties’ motion is deficient. First, the parties failed to provide 11 a declaration from counsel, as required by the Court’s Chambers Rules and the Court’s 12 January 30, 2023, Order. Chmb.R. at 2 (requiring that the joint motion for continuance 13 include a “declaration from counsel seeking the continuance that describes the steps taken 14 to comply with the existing deadlines, and the specific reasons why the deadlines cannot 15 be met”); ECF No. 4 at 6 (same). The Court will take the parties at their words without the 16 required declaration, but will not do so again. 17 Second, the parties’ Confidential ENE Statements and Participant Lists were due on 18 March 2, 2023, (see ECF No. 4 at 2, 5), and the instant motion to continue the ENE and 19 the deadline for submission of ENE Statements was filed on March 2, 2023. ECF No. 6. 20 By filing the motion on same date as the affected deadline, the parties failed to follow the 21 Court’s Chambers Rules and the Court’s January 30, 2023, Order. See Chmb.R. at 2 22 (requiring that “[a]ll requests for continuances must be made by a joint motion no less than 23 seven calendar days before the affected date”) (emphasis added); ECF No. 4 at 6 (same). 24 The Court expresses its deep concern in the parties’ blatant disregard for the Court’s 25 Chambers Rules. 26 Third, the parties’ motion failed to include specific facts or any framework for a 27 finding of good cause. The motion merely recounts that “a person with authority for 28 Defendant [] is unavailable for the ENE video-conference on March 9, 2023.” ECF No. 6 1 at 2. Without more, this is simply insufficient. However, court staff reached out to the 2 parties for more detailed reasoning regarding the requested continuance and Defendant 3 responded, explaining the representative’s personal commitments. The details provided to 4 court staff should have been included in the required declaration. 5 Despite the joint motion’s shortcomings, upon receipt of the supplemental 6 information, the Court finds good cause to continue the ENE and CMC. As such, the 7 parties’ joint motion is GRANTED IN PART as follows: 8 1. The ENE, originally scheduled for March 9, 2023, is hereby RESET for 9 May 3, 20231 at 2:00 p.m. before Magistrate Judge Allison H. Goddard via 10 videoconference. In accordance with the Local Rules, the Court requires attendance of all 11 parties, party representatives, including claims adjusters for insured defendants, and the 12 primary attorney(s) responsible for the litigation via videoconference. CivLR 16.1(c)(1). 13 2. Purpose of the Conference: The purpose of the ENE is to permit an informal 14 discussion between the attorneys and the settlement judge of every aspect of the lawsuit in 15 an effort to achieve an early resolution of the case. All conference discussions will be 16 informal, off the record, and confidential. 17 3. Full Settlement Authority Required: A party or party representative with 18 full and complete authority to enter into a binding settlement must be present via 19 videoconference. Full authority to settle means that a person must be authorized to fully 20 explore settlement options and to agree at that time to any settlement terms acceptable to 21 the parties. Heileman Brewing Co., Inc. v. Joseph Oat Corp., 871 F.2d 648, 653 (7th Cir. 22 1989). The person needs to have “unfettered discretion and authority” to change the 23 settlement position of a party. Pitman v. Brinker Int’l, Inc., 216 F.R.D. 481, 485–86 (D. 24 Ariz. 2003). Limited or sum certain authority is not adequate. Nick v. Morgan’s Foods, 25 26 1 The Court appreciates that the parties identified dates in March that were mutually 27 agreeable. See ECF No. 6 at 2. However, the Court does not have availability on those dates and has set the continued ENE for the first available date on its calendar. 28 1 Inc., 270 F.3d 590, 595–97 (8th Cir. 2001). A person who needs to call another person 2 who is not present on the videoconference before agreeing to any settlement does not 3 have full authority. 4 4. Confidential ENE Statements Required: No later than April 26, 2023,2 the 5 parties shall submit confidential statements of five (5) pages or less directly to the chambers 6 of Magistrate Judge Goddard outlining the nature of the case, the claims, and the defenses. 7 These statements shall not be filed or served on opposing counsel. They shall be lodged 8 via email at efile_goddard@casd.uscourts.gov. The ENE statement is limited to five (5) 9 pages or less, and up to five (5) pages of exhibits or declarations. Each party’s ENE 10 statement must outline: 11 A. the nature of the case and the claims, 12 B. position on liability or defense, 13 C. position regarding settlement of the case with a specific3 14 demand/offer for settlement,4 and 15 D. any previous settlement negotiations or mediation efforts. 16 5. Case Management Conference: In the event the case does not settle at the 17 ENE, the Court will immediately thereafter hold a CMC pursuant to Fed. R. Civ. P. 16(b). 18 Appearance of the parties at the CMC is not required. The deadlines previously set (see 19 ECF No. 4) remain in place, but are repeated for the parties’ convenience: 20 / / 21

22 2 Plaintiff timely submitted her ENE Statement by the initial deadline of March 2, 2023. 23 Thus, Plaintiff is not required to submit an ENE Statement by the continued April deadline. 24 Should Plaintiff prefer to send an updated ENE statement, though, she may do so.

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Kersting v. UnitedHealth Group, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kersting-v-unitedhealth-group-casd-2023.