May v. UnumProvident Corporation et al

Filing 16

STIPULATION AND ORDER that Defendants shall have an extension to respond to the complaint from 3/8/2010 to and including up to 5/10/2010. The case management conference shall be continued from 4/22/2010 to 6/24/2010, re doc 15 filed by Paul Revere Life Insurance Company, Unum Group, UnumProvident Corporation. Signed by Judge Vaughn R Walker on 3/10/2010. (cgk, COURT STAFF) (Filed on 3/10/2010)

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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 521662.1

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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. 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. 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 March 8, 2010 to May 10, 2010. In the alternative, if the CMC date is not continued, the parties stipulate that defendants' responsive pleading shall be extended from March 8, 2010 to March 29, 2010. The parties further stipulate to continue the Case Management Conference presently scheduled for April 22, 2010 to June 24, 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: March 8, 2010

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

Dated: March 8, 2010 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

521662.1

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ORDER IT IS SO ORDERED that defendants shall have an extension to respond to the complaint from March 8, 2010 to and including [March 29, 1010 or May 10, 2010]. It is further ordered that the Case Management Conference is continued from April 22, 2010 to June 24, 2010.
TC T ___________________________________ TA VAUGHN R. WALKER United States DistrictEChief Judge D RED

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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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