Jaquish v. The Standard Insurance Company

Filing 10

SECOND STIPULATION and ORDER TO EXTEND TIME TO RESPOND TO COMPLAINT. The deadline for Defendants to respond to the complaint is hereby extended from February 27, 2018, through March 13, 2018. Order signed by Magistrate Judge Sheila K. Oberto on 3/1/2018. (Timken, A)

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275 Battery Street, Suite 2000
San Francisco, CA 94111

Gordon Rees Scully Mansukhani, LLP

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JORDAN S. ALTURA (SBN: 209431)
TINO X. DO (SBN: 221346)
GORDON REES SCULLY MANSUKHANI, LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Defendants
THE STANDARD INSURANCE COMPANY,
an Oregon Corporation; THE STANDARD
INSURANCE COMPANY, an Oregon Corporation
as administrator of the CALIFORNIA TEACHERS
ASSOCIATION ECONOMICS BENEFITS
TRUST GROUP DISABILITY POLICY
ALLAN BAILEY (SBN: 258295)
ALEXANDER REED-KRASE (SBN: 272603)
KRASE, BAILEY, REED-KRASE, LLP
132 East Morton Avenue
Porterville, CA 93257
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
YVETTE L. JAQUISH

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA – FRESNO

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YVETTE L. JAQUISH, an individual,
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)
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Plaintiff,
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vs.
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THE STANDARD INSURANCE COMPANY, )
an Oregon Corporation; THE STANDARD
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INSURANCE COMPANY, an Oregon
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Corporation as administrator of the
)
CALIFORNIA TEACHERS ASSOCIATION
)
ECONOMICS BENEFITS TRUST GROUP
DISABILITY POLICY and DOES 1 through 100, )
)
Defendants.
)

Case No. 1:18-cv-00087-LJO-SKO
SECOND JOINT STIPULATION TO
EXTEND TIME TO RESPOND TO
COMPLAINT (L.R. 144(A)); ORDER
ON STIPULATION
Complaint Filed: 1/18/2018
(Doc. 9)

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AETNA/1130147/31163982v.1

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SECOND JOINT STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT;
ORDER ON STIPULATION
CASE NO. 1:18-cv-00087-LJO-SKO

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TO THE HONORABLE COURT:

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The parties hereto, Plaintiff YVETTE L. JAQUISH (“Plaintiff”) and Defendant THE

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STANDARD INSURANCE COMPANY an Oregon Corporation; THE STANDARD

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INSURANCE COMPANY, an Oregon Corporation as administrator of the CALIFORNIA

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TEACHERS ASSOCIATION ECONOMICS BENEFITS TRUST GROUP DISABILITY

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POLICY (“Defendants”), by and through their respective counsel of record, hereby stipulate as

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follows:
WHEREAS, Plaintiff filed her Complaint in this Court on January 18, 2018.

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WHEREAS, Plaintiff served the Complaint onto Defendants on January 23, 2018.

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275 Battery Street, Suite 2000
San Francisco, CA 94111

Gordon Rees Scully Mansukhani, LLP

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WHEREAS, the parties have entered into a previous Stipulation to Extend Time to
Respond to Complaint on February 2, 2018.
WHEREAS, Defendants’ current deadline to file a response to the Complaint is
February 27, 2018.

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WHEREAS, Defendants have requested an extension of an additional 14 days, or until

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March 13, 2018, to respond to the Complaint in order to permit sufficient time to prepare a

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response.

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WHEREAS, Plaintiff and Defendants do not anticipate that this extension of time will
alter the date of any event or any deadline already fixed by Court order.

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IT IS HEREBY STIPULATED by and between Plaintiff and Defendants through their

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respective counsel of record that the deadline for Defendants to respond is extended up to

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March 13, 2018.

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IT IS SO STIPULATED.
Dated: February 27, 2018

KRASE, BAILEY, REED-KRASE, LLP

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By /s/ Alexander Reed-Krase
Allan Bailey
Alexander Reed-Krase
Attorneys for Plaintiff
YVETTE L. JAQUISH

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SECOND JOINT STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT;
ORDER ON STIPULATION
CASE NO. 1:18-cv-00087-LJO-SKO

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Dated: February 27, 2018

GORDON REES SCULLY MANSUKHANI LLP

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By /s/ Jordan S. Altura
Jordan S. Altura
Tino X. Do
Attorneys for Defendants
THE STANDARD INSURANCE COMPANY an
Oregon Corporation; THE STANDARD
INSURANCE COMPANY, an Oregon Corporation
as administrator of the CALIFORNIA TEACHERS
ASSOCIATION ECONOMICS BENEFITS
TRUST GROUP DISABILITY POLICY

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ATTESTATION OF E-FILED SIGNATURE
I, Jordan S. Altura, am the ECF user whose ID and password are being used to file this
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Second Joint Stipulation to Extend Time to Respond to Complaint. In compliance with Local
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275 Battery Street, Suite 2000
San Francisco, CA 94111

Gordon Rees Scully Mansukhani, LLP

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Rule 5-1(i), I hereby attest that Alexander Reed-Krase, counsel for Plaintiff, has concurred in
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this filing.
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Dated: February 27, 2018

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/s/ Jordan S. Altura
Jordan S. Altura

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ORDER

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Pursuant to the parties’ above stipulation to extend the time for Defendants The Standard

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Insurance Company an Oregon Corporation, and The Standard Insurance Company, an Oregon

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Corporation as administrator of the California Teachers Association Economics Benefits Trust

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Group Disability Policy (collectively “Defendants”) to respond to the complaint (Doc. 9), and for

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good cause shown, IT IS ORDERED that the deadline for Defendants to respond to the

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complaint is hereby extended from February 27, 2018, through March 13, 2018.

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IT IS SO ORDERED.
Dated:

March 1, 2018

/s/

Sheila K. Oberto

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UNITED STATES MAGISTRATE JUDGE

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SECOND JOINT STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT;
ORDER ON STIPULATION
CASE NO. 1:18-cv-00087-LJO-SKO