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Deborah Jacobs v. Life Insurance Company of North America and United Airlines Long Term Disability Plan

December 22, 2011

DEBORAH JACOBS,
PLAINTIFF,
v.
LIFE INSURANCE COMPANY OF NORTH AMERICA AND UNITED AIRLINES LONG TERM DISABILITY PLAN,
DEFENDANTS.



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

ORDER

PURSUANT TO STIPULATION, IT IS ...


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