Rizzotti v. Central Pacific Mortgage Company Long Term Disability Plan

Filing 32

STIPULATION AND ORDER extending time to respond to complaint. Signed by Judge Thelton E. Henderson on 02/19/09. (rbe, COURT STAFF) (Filed on 2/19/2009)

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BARGER & WOLEN LLP
19800 MACARTHUR BLVD. EIGHTH FLOOR IRVINE, CA 92612 [phone]

Robert J. McKennon (123176), [e-mail] Scott E. Calvert (210787), [e-mail]

BARGER & WOLEN LLP

19800 MacArthur Boulevard, 8th Floor Irvine, California 92612 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant The Prudential Insurance Company of America (erroneously sued as Prudential Financial) Thornton Davidson, Esq. (166487) [e-mail] THE ERISA LAW GROUP 2055 San Joaquin Street Fresno, California 93721-2717 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff Carrie Rizzotti UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ­ SAN FRANCISCO CARRIE RIZZOTTI Plaintiffs, vs. CENTRAL PACIFIC MORTGAGE COMPANY LONG TERM DISABILITY PLAN; PRUDENTIAL FINANCIAL, Defendants. Case No.: 3:08-cv-02749 TEH Action Filed : 06/02/2008 STIPULATION OF COUNSEL FOR AN EXTENSION OF TIME WITHIN WHICH DEFENDANT MAY RESPOND TO PLAINTIFF'S COMPLAINT [Local Rule 6-1]

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STIPULATION OF COUNSEL FOR AN EXTENSION OF TIME

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Case No.: 3:08-cv-02749 TEH

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BARGER & WOLEN LLP
19800 MACARTHUR BLVD. EIGHTH FLOOR IRVINE, CA 92612 [phone]

Pursuant to Rule 6-1 of the Local Rules of Practice for the United States District Court for the Northern District of California ("Local Rules"), Plaintiff Carrie Rizzotti ("Plaintiff") and Defendant The Prudential Insurance Company of America ("Defendant"), by and through their respective counsel, hereby stipulate to extend the time within which Defendant may answer or otherwise respond to the Complaint filed by Plaintiff on February 17, 2009 and served by request for waiver of service of summons upon Defendant on December 16, 2008. Specifically, Defendant shall have an additional fourteen (14) days from the response date in which to answer or otherwise respond, such that a pleading filed on or before March 3, 2009 shall be deemed timely. Good cause exists for this extension because additional time is needed to gather all relevant plan documents and all matters previously reviewed and considered in connection with Plaintiff's disability claim (i.e., the "Administrative Record"), to formulate their interim litigation strategy and to prepare their actual responsive pleadings. As provided by Local Rule 6-1, this stipulation "will not alter the date of any event or any deadline already fixed by Court order." Dated: February 17, 2009
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BARGER & WOLEN LLP
By: /s/ Scott E. Calvert ROBERT J. MCKENNON SCOTT E. CALVERT Attorneys for Defendant The Prudential Insurance Company of America

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STIPULATION OF COUNSEL FOR AN EXTENSION OF TIME

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Case No.: 3:08-cv-02749 TEH

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BARGER & WOLEN LLP
19800 MACARTHUR BLVD. EIGHTH FLOOR IRVINE, CA 92612 [phone]

Dated: February 17, 2009

THE ERISA LAW GROUP
By: /s/ Thornton Davidson THORNTON DAVIDSON Attorneys for Plaintiff Carrie Rizzotti

STIPULATION OF COUNSEL FOR AN EXTENSION OF TIME

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Case No.: 3:08-cv-02749 TEH