The opinion of the court was delivered by: The Honorable Saundra B. Armstrong United States District Court Judge
SEAN P. NALTY (SBN: 121253) Email: firstname.lastname@example.org SHIVANI NANDA (SBN: 253891) Email: email@example.com WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP 525 Market Street -- 17th Floor San Francisco, California 94105-2725 Telephone: (415) 433-0990 Facsimile: (415) 434-1370 Attorneys for Defendant, LIFE INSURANCE COMPANY OF NORTH AMERICA TERESA S. RENAKER (SBN: 187800) Email: firstname.lastname@example.org JULIE WILENSKY (SBN: 271765) Email: email@example.com LEWIS, FEINBERG, LEE, RENAKER & JACKSON, P.C. 476 -- 9th Street Oakland, California 94607 Telephone: (510) 839-6824 Facsimile: (510)839-7839 13 Attorneys for Plaintiff, JOHN DOE
STIPULATION AND ORDER TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT Action Filed: July 29, 2011 Trial Date: None 22
IT IS HEREBY STIPULATED, pursuant to Local Rule 6-2, by and between plaintiff John Doe and defendant Life Insurance Company of North America ("LINA"), through their 26 attorneys of record, as follows: 27
1. LINA was served with the Summons and Complaint on August 2, 2011; 25
2. The parties previously stipulated that LINA may have extension to and including September 21, 2011 to answer or otherwise respond to the Complaint;
3. The parties have resolved Plaintiff's claim for benefits and are in discussions regarding Plaintiff's claim for interest and attorneys fees;
4. To enable the parties to continue working towards resolving all
issues in dispute,
the parties have agreed that LINA may have an extension to and
including October 5, 2011 to 6 answer or otherwise respond to the
Complaint; and 7
4. This extension of time to respond to the Complaint does not alter the date of any event or any deadline already fixed by Court Order. 9 10
I hereby attest that I have on file all holograph signatures for any signatures indicated by a "conformed" signature (/s/) within this efiled document.
/s/ Shivani Nanda SHIVANI NANDA WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP 525 Market Street, 17th Floor San Francisco, California 94105 Tel: (415) 433-0990 Fax: (415) 434-1370
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