May v. UnumProvident Corporation et al

Filing 11

STIPULATION AND ORDER. Defendants shall have an extension to respond to the complaint from 11/23/2009 to and including 1/22/2010. The case management conference shall be continued from 12/17/2009 to 2/11/2010 at 3:30 PM re doc 10 filed by Paul Revere Life Insurance Company, Unum Group, UnumProvident Corporation. Signed by Judge Vaughn R Walker on 11/24/2009. (cgk, COURT STAFF) (Filed on 11/24/2009)

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THOMAS M. HERLIHY (SBN 83615) JOHN T. BURNITE (SBN 162223) WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP 525 Market Street, 17th Floor San Francisco, CA 94105-2725 Tel.: [phone] Fax: [phone] Email: [e-mail] [e-mail] Attorneys for Defendants UNUM GROUP (formerly known as UNUMPROVIDENT CORPORATION) and THE PAUL REVERE LIFE INSURANCE COMPANY

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ) ) ) Plaintiff, ) ) vs. ) UNUMPROVIDENT CORPORATION, THE ) ) PAUL REVERE LIFE INSURANCE ) COMPANY and UNUM GROUP, inclusive, ) ) Defendants. ) ) SEAN S. MAY, M.D. Case No.: C09-01537 VRW (ADR) STIPULATION TO EXTEND RESPONSIVE PLEADING DEADLINE AND TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER

STIPULATION TO EXTEND RESPONSIVE PLEADING DEADLINE AND TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER 491332.1

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The parties, plaintiff Sean S. May, M.D. and defendants Unum Group (formerly known as UnumProvident Corporation), and The Paul Revere Life Insurance Company are in the process of discussing settlement, which may include setting an early mediation within the next 60 days. Accordingly, the parties, through their respective attorneys, respectfully request that the court approve this stipulation and extend defendants' responsive pleading deadline and the initial case management conference by 60 days. Pursuant to Northern District Local Rule 6-1(a), the parties, hereby stipulate that defendants shall have an extension to respond to the complaint from November 23, 2009 to and including January 22, 2010. The parties further stipulate to continue the Case Management Conference presently scheduled for December 17, 2009 to February 11, 2010. Good cause exists for the parties' stipulation and proposed order insofar the continued dates will promote the public policy of encouraging parties to explore early resolution of litigation. IT IS SO STIPULATED. KNOX RICKSEN, LLP

Dated: November 19, 2009

By__________/s/_________________ Thomas E. Fraysse Attorney for Plaintiff SEAN S. MAY, M.D. WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP

Dated: November 19, 2009 25 26 27 28

By__________/s/____________________ Thomas M. Herlihy John T. Burnite Attorney for Defendants UNUM GROUP (formerly known as UNUMPROVIDENT CORPORATION) and THE PAUL REVERE LIFE INSURANCE COMPANY

-1STIPULATION TO EXTEND RESPONSIVE PLEADING DEADLINE AND TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
Case No.: C09-01537VRW (ADR0

491332.1

1 2 3 4 5 6 7 8 9 10 11 24 Date: November ___, 2009 ORDER IT IS SO ORDERED that defendants shall have an extension to respond to the complaint from November 23, 2009 to and including January 22, 2010. It is further ordered that the Case Management Conference is continued from December 17, 2009 to February 11, 2010.

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-2STIPULATION TO EXTEND RESPONSIVE PLEADING DEADLINE AND TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
Case No.: C09-01537VRW (ADR0

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