Polanco v. Genentech, Inc.'s Group Long Term Disability Insurance Plan

Filing 6

STIPULATION AND ORDER. Signed by Magistrate Judge Bernard Zimmerman on 8/17/2009. (bzsec, COURT STAFF) (Filed on 8/17/2009)

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ADRIENNE C. PUBLICOVER (SBN 161432) Email: [e-mail] DENNIS J. RHODES (SBN 168417) Email: [e-mail] WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP 525 Market Street, 17th Floor San Francisco, CA 94105 Tel: [phone] / Fax: [phone] Attorneys for Real Party In Interest RELIANCE STANDARD LIFE INSURANCE COMPANY LAURENCE F. PADWAY (SBN 083914) Email: [e-mail] LAW OFFICES OF LAURENCE F. PADWAY 1516 Oak Street, Suite 109 Alameda, CA 94501 Tel: [phone] / Fax: [phone] Attorneys for Plaintiff VICTOR POLANCO UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

) ) Plaintiff, ) ) v. ) ) GENENTECH, INC.'S GROUP LONG TERM ) DISABILITY INSURANCE PLAN, ) ) Defendant, ) ) ) RELIANCE STANDARD LIFE INSURANCE ) COMPANY, ) ) Real Party in Interest. ) )

VICTOR POLANCO,

Case No.:

CV09-03188 BZ

STIPULATION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT; AND [PROPOSED] ORDER [Local Rule 6-1]

IT IS HEREBY STIPULATED, pursuant to Local Rule 6-1, by and between Plaintiff Victor Polanco and Real Party In Interest Reliance Standard Life Insurance Company, through their attorneys of record, as follows:
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1.

The response Real Party In Interest Reliance Standard Life Insurance Company to

plaintiff's Complaint currently are due on August 17, 2009; 2. The parties have agreed that Real Party In Interest Reliance Standard Life

Insurance Company may have a 15 day extension, to and including September 1, 2009 to answer or otherwise respond to the Complaint herein; and 3. Court order. Date: August 14, 2009 WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP This extension will not alter the date of any event or any deadline already fixed by

By:

/s/ Dennis J. Rhodes ADRIENNE C. PUBLICOVER DENNIS J. RHODES Attorneys for Real Party In Interest RELIANCE STANDARD LIFE INSURANCE COMPANY

Date: August 14, 2009

LAW OFFICES OF LAURENCE F. PADWAY

By:

/s/ Laurence F. Padway LAURENCE F. PADWAY Attorneys for Plaintiff VICTOR POLANCO

ORDER IT IS SO ORDERED.

Date: August 17, 2009

By: HONORABLE BERNARD ZIMMERMAN UNITED STATES MAGISTRATE JUDGE

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CERTIFICATE OF SERVICE Victor Polanco v. Genentech, Inc.'s Group Long Term Disability Insurance Plan / Reliance Standard Life Insurance Company USDC NDCA Case #CV09-03188 BZ I am over the age of eighteen years and am not a party to the within cause. I am employed in the City and County of San Francisco, California and my business address are 525 Market Street, 17th Floor, and San Francisco, California 94105-2725. On this date I served the following document(s): STIPULATION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT; AND [PROPOSED] ORDER on the part(y)(ies) identified below, through their attorneys of record, by placing true copies thereof in sealed envelopes addressed as shown below by the following means of service: : By First Class Mail -- I caused each such envelope, with first class postage thereon fully prepaid, to be deposited in a recognized place of deposit of the U.S. Mail in San Francisco, California, for collection to the office of the addressee following ordinary business practices. : By Personal Service -- I caused each such envelope to be given to a courier messenger who personally delivered each such envelope to the office of the address. : By Overnight Courier -- I caused each such envelope to be given to an overnight mail service at San Francisco, California, to be hand delivered to the addressee on the next business day. : Facsimile -- (Only where permitted. Must consult CCP §1012.5 and California Rules of Court 2001-2011. Also consult FRCP Rule 5(e). Not currently authorized in N.D.CA.) Laurence F. Padway, Esq. L/O OF LAURENCE F. PADWAY 1516 Oak Street, Suite 109 Alameda, CA 94501 Tel: [phone] Fax: [phone] Attorneys for Plaintiff VICTOR POLANCO I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct to the best of my knowledge. EXECUTED on August 17, 2009, at San Francisco, California.

Nancy Li

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