UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
December 22, 2011
LIFE INSURANCE COMPANY OF NORTH AMERICA AND UNITED AIRLINES LONG TERM DISABILITY PLAN,
The opinion of the court was delivered by: Honorable Charles R. Breyer United States District Court Judge
SECOND STIPULATION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT; AND [PROPOSED] ORDER
Action Filed: November 8, 2011 Trial Date: None plaintiff Deborah Jacobs and defendants Life Insurance Company of North America ("LINA") 3 and United Airlines Employee Welfare Benefit Plan (sued herein as "United Airlines Long Term 4
1. Defendants LINA and United Airlines Employee Welfare Benefit Plan were served with the Summons and Complaint in this action on November 10, 2011; Airlines Employee Welfare Benefit Plan would have an extension to and including December 9
3. A Stipulation To Extend Time To Answer Or Otherwise Respond To Plaintiff's Complaint, granting the defendants an extension to December 30, 2011, was filed in this action 12 on November 22, 2011; 13
During the week of December 26, 2011, Charan M. Higbee, attorney for the defendants, will be 15 on vacation. During this same week, client representatives of both defendants also are on 16 vacation. For this reason, defendants and their attorneys will not be able to finalize the Answer 17 during the week of December 26, 2011. 18
Employee Welfare Benefit Plan may have an extension to an including January 6, 2012 to 20 answer or otherwise respond to the Complaint filed in this action; and event or any deadline already fixed by Court Order.
IT IS HEREBY STIPULATED, pursuant to Local Rules 6-1 and 6-2, by and between Disability Plan"), through their attorneys of record, as follows:
2. The parties to this action initially agreed that Defendants LINA and United 30, 2011 to answer or otherwise respond to the Complaint filed in this action;
4. Defendants need additional time to prepare their Answer to the Complaint.
5. The parties to this action have agreed that Defendants LINA and United Airlines
6. This extension of time to respond to the Complaint does not alter the date of any
Date: December 22, 2011 WILSON, ELSER, MOSKOWITZ, 1 EDELMAN & DICKER LLP By: /s/ Charan M. Higbee ADRIENNE C. PUBLICOVER CHARAN M. HIGBEE Attorneys for Defendants LIFE INSURANCE COMPANY OF NORTH AMERICA and UNITED AIRLINES EMPLOYEE WELFARE BENEFIT PLAN (sued herein as "UNITED AIRLINES LONG TERM DISABILITY PLAN") Date: December 22, 2011 LEWIS, FEINBERG, LEE, RENAKER 9 & JACKSON, P.C. By: _/s/ Nina Wasow_____________ TERESA RENAKER NINA WASOW Attorneys for Plaintiff DEBORAH JACOBS
PURSUANT TO STIPULATION, IT IS HEREBY ORDERED:
Defendants Life Insurance Company of North America and United Airlines Employee Welfare Benefit Plan (sued as "United Airlines Long Term Disability Plan") have an extension 19 to and including January 6, 2012 to answer or otherwise respond to plaintiff's Complaint in this 20 action. ES DIST I
Date: December 29, 2011
By: S O
IT IS SO ORDERED
Charles R. Breyer Judge
employed by WILSON, ELSER, MOSKOWITZ, EDEL th MAN & DICKER LLP. My business address is 525 Market Street, 17 Floor, San Francisco, California 94105. My business 5 telephone number is (415) 433-0990; my business fax number is (415) 434-1370. On this date I served the following document(s): 6
CERTIFICATE OF SERVICE
Jacobs v. Life Insurance Company of North America, et al.
U.S.D.C. Northern District of California Case No.: C11-05418-CRB
At the time of service I was over 18 years of age and not a party to this action. I am
SECOND STIPULATION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT AND [PROPOSED] ORDER
on the person or persons listed below, through their respective attorneys of record in this action, 9 by placing true copies thereof in sealed envelopes or packages addressed as shown below by the following means of service: 10
service by electronic transmission, I caused the documents to be sent to the persons at the electronic notification addresses listed below.
Teresa Renaker Nina Wasow Lewis, Feinberg, Lee, Renaker & Jackson, P.C. 476-9th Street Oakland, CA 94607 Ph: 510.839.6824 Fax: 510.839.7839 firstname.lastname@example.org email@example.com
By Electronic Service. Based on a court order or an agreement of the parties to accept foregoing is true and correct to the best of my knowledge. Attorneys for Plaintiff, Deborah Jacobs
I declare under penalty of perjury under the laws of the State of California that the EXECUTED on December 22, 2011 at San Francisco, California.
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