IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA
April 24, 2012
RELIANCE STANDARD LIFE INSURANCE COMPANY AS ADMINISTRATOR AND FIDUCIARY OF THE GENENTECH, INC., LONG TERM
DISABILITY INSURANCE PLAN AND THE GENENTECH, INC., LONG TERM DISABILITY INSURANCE PLAN, DEFENDANTS.
The opinion of the court was delivered by: Honorable Jeffrey S. White United States District Judge
STIPULATION TO EXTEND TIME TO ADVISE COURT OF OUTCOME OF DISCUSSIONS PURSUANT TO ORDER ON CROSS-MOTIONS FOR SUMMARY JUDGMENT; AND [PROPOSED] ORDER [Local Rule 6-1]
IT IS HEREBY STIPULATED, pursuant to Local Rule 6-1, by and between Plaintiff Isela Dimery ("Plaintiff"), defendant Reliance Standard Life Insurance Company ("Reliance Standard"), and defendant The Genentech, Inc. Long Term Disability Insurance Plan ("the Plan") 2 (collectively Reliance Standard and the Plan referred to as "Defendants"), through their attorneys 3 of record, as follows:
4 1. Pursuant to this Court's order dated March 28, 2012, the Parties are required to 5 report by to the Court by April 30, 2012 as to whether they have reached agreement on the amount 6 of the offset awarded to Reliance Standard. The Parties are still discussing the issue and need 7 additional time to complete their discussions. 8 2. In view of ongoing discussions, the parties agree that an extension of time from April 30, 2012 to May 21, 2012 should allow them to complete their meet and confer sessions. 10 3. This extension will not alter the date of any event or any deadline already fixed by 9 Court order. 12
Based on the foregoing, the Parties respectfully request that the date for reporting to the 13 court be extended from April 30, 2012 to May 21, 2012. 14
Dated: April 23, 2012 WILSON, ELSER, MOSKOWITZ, 15 EDELMAN & DICKER LLP 11 16 By: /s/ Dennis J. Rhodes Adrienne Publicover 17 Dennis J. Rhodes Attorneys for Defendants 18 RELIANCE STANDARD LIFE INSURANCE COMPANY and THE GENENTECH, INC., LONG 19 TERM DISABILITY INSURANCE PLAN Dated: April 23, 2010 ROBOOSTOFF & KALKIN 21 By: /s/ Scott Kalkin 20 Scott Kalkin 22 Attorneys for Plaintiff ISELA DIMERY
IT IS SO ORDERED.
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