Bilbrey v. Reliance Standard Insurance Company et al

Filing 68

STIPULATION AND ORDER extending time to 7/26/2010 to file 2nd amended complaint; Further Case Management Conference continued to 8/30/2010 03:00 PM in Courtroom 15, 18th Floor, San Francisco; Signed by Judge Marilyn Hall Patel on 6/21/2010. (awb, COURT STAFF) (Filed on 6/22/2010)

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STEVEN P. KRAFCHICK (WA SBN 13542) KRAFCHICK LAW FIRM 100 W. Harrison, South Tower, Suite 300 Seattle, WA 98119 Tel: [phone], Fax: [phone] E-mail: [e-mail] Appearing Pro Hac Vice ABRAHAM N. GOLDMAN (SBN 102080) ABRAHAM N. GOLDMAN & ASSOCIATES, LTD P.O. BOX 120 / 12896 Rices Crossing Road Oregon House, CA 95962-0120 Tel: [phone] Fax: [phone] E-mail: [e-mail] Attorneys for Plaintiff CHAD BILBREY 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, California 94105 Tel: [phone] Fax: [phone] Attorneys for Defendants RELIANCE STANDARD INSURANCE COMPANY, MATRIX ABSENCE MANAGEMENT, INC. and GROUP WELFARE BENEFIT PLAN UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA CHAD BILBREY, ) ) Plaintiff, ) v. ) ) RELIANCE STANDARD INSURANCE ) COMPANY, MATRIX ABSENCE ) MANAGEMENT, INC., GROUP WELFARE ) BENEFIT PLAN, LAM RESEARCH ) CORPORATION, ) ) Defendants, ) ) ) //
1 2ND STIPULATION TO EXTEND TIME TO FILE SECOND AMENDED COMPLAINT TO JULY 26, 2010; AND TO RESET STATUS CONFERENCE;[PROPOSED] ORDER THEREON Case No.: 09-cv-03399 MHP

Case No.: 09-cv-03399 MHP SECOND STIPULATION TO EXTEND TIME TO FILE SECOND AMENDED COMPLAINT TO JULY 26, 2010; AND TO RESET STATUS CONFERENCE; [PROPOSED] ORDER THEREON [Local Rule 6-2] Courtroom: 15 Judge: The Hon. Marilyn H. Patel Supporting Documents 1. Declaration of Abraham N. Goldman

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IT IS HEREBY STIPULATED, pursuant to Local Rule 6-2, by and between Plaintiff Chad Bilbrey and Defendants Reliance Standard Insurance Company ("Reliance Standard"), Matrix Absence Management, Inc. ("Matrix"), Group Welfare Benefit Plan and LAM Research Corporation, through their attorneys of record, that the time for plaintiff to file his Second Amended Complaint, currently set for June 25, 2010, shall be continued to July 26, 2010. Further, if this stipulation is granted, the parties stipulate and request that the Status Conference, which was previously continued by the Court from May 17, 2010 to July 26, 2010, be continued to a date after July 26, 2010, convenient for the calendars of the parties and the Court. As set forth in the attached Declaration, the parties are currently engaged in serious and significant settlement discussion. The parties are optimistic that these negotiations will result in the complete resolution of this matter before a new Amended Complaint needs to be filed and another Status Conference needs to be held. Pursuant to Local Rule 6-2, the declaration of Abraham N. Goldman in support of this motion is filed contemporaneously with this stipulation and order. Dated: June 17, 2010
WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP

By: /s/ Dennis J. Rhodes ADRIENNE C. PUBLICOVER DENNIS J. RHODES, Attorneys for Defendants RELIANCE STANDARD INSURANCE CO. MATRIX ABSENCE MANAGEMENT, INC. and GROUP WELFARE BENEFIT PLAN Dated: June 17, 2010 ABRAHAM GOLDMAN & ASSOCIATES LTD. Per: /s/ Abraham Goldman ABRAHAM GOLDMAN, Attorney for Plaintiff CHAD BILBREY KRAFCHICK LAW FIRM. Per: /s/ Steven P. Krafchick STEVEN P. KRAFCHICK, Attorney for Plaintiff CHAD BILBREY ORDER

Dated: June 17, 2010

Pursuant to stipulation of the parties, the time for plaintiff to file his Second Amended Complaint is extended from June 25, 2010 to July 26, 2010. The Status Conference reset from

2 2ND STIPULATION TO EXTEND TIME TO FILE SECOND AMENDED COMPLAINT TO JULY 26, 2010; AND TO RESET STATUS CONFERENCE;[PROPOSED] ORDER THEREON Case No.: 09-cv-03399 MHP

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at 3:00 p.m. August 30 2010, with a Joint Supplemental May 17, 2010 to July 26, 2010, is hereby reset to__________, Status report to be filed one week prior to the Status Conference. IT IS SO ORDERED. Dated: June 21, 2010 By:

HONORABLE MARILYN H. PATEL D UNITED STATES DISTRICT ERE O ORD JUDGE

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3 2ND STIPULATION TO EXTEND TIME TO FILE SECOND AMENDED COMPLAINT TO JULY 26, 2010; AND TO RESET STATUS CONFERENCE;[PROPOSED] ORDER THEREON Case No.: 09-cv-03399 MHP

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