Fischbach-Benson v. Life Insurance Company of North America et al

Filing 10

STIPULATION AND ORDER that the deadline for defendant Life Insurance Company of North America to respond to Plaintiff's complaint is extended to April 5, 2010. Signed by Judge Samuel Conti on 3/8/10. (tdm, COURT STAFF) (Filed on 3/8/2010)

1 ADRIENNE C. PUBLICOVER (SBN 161432) SHIVANI NANDA (SBN 253891) 2 WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP 3 525 Market Street, 17th Floor San Francisco, California 94105 4 Tel: [phone] Fax: [phone] Email: [e-mail] [e-mail] 6 7 Attorneys for Defendant 8 LIFE INSURANCE COMPANY OF NORTH AMERICA 9 10 11 12 13 DINAH FISCHBACH-BENSON, 14 15 v. Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) CASE NO. CV 10-00036 SC UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

16 LIFE INSURANCE COMPANY OF NORTH AMERICA, INSURANCE 17 COMPANY OF NORTH AMERICA, and DOES 1 through 10, 18 Defendants. 19 20 21

STIPULATION TO EXTEND TIME TO RESPOND TO PLAINTIFF'S INITIAL COMPLAINT, PURSUANT TO LOCAL RULE 6-1 Action Filed: Date of Removal: Current Response Due: New Response Date: September 25, 2009 January 5, 2010 March 5, 2010 April 5, 2010

Plaintiff Dinah Fischbach-Benson, and defendant Life Insurance Company of North America,

22 through their attorneys of record, hereby submit this stipulation to extend the deadline for defendant to 23 respond to Plaintiff's complaint by 30 days: 24 WHEREAS, Defendant Life Insurance Company of North America removed this action on

25 January 5, 2010. 26 27 28
1 STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT PURSUANT TO LOCAL RULE 6-1 USDC NDCA Case # CV10-00036 SC
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WHEREAS, the parties stipulated that defendant Life Insurance Company of North America's

1 response to Plaintiff's complaint would be due on Friday, February 5, 2010; 2 WHEREAS, the parties have reached a settlement of all claims and counsel have finalized the

3 terms of a written settlement agreement and release; 4 WHEREAS, counsel have forwarded the agreed upon settlement agreement and release to their

5 respective clients for signatures; 6 WHEREAS, given the parties' settlement, the parties stipulated to an additional 30-day

7 extension of the deadline for defendant Life Insurance Company of North America to respond to the 8 complaint; 9 /// 10 /// 11 /// 12 /// 13 /// 14 /// 15 /// 16 /// 17 /// 18 /// 19 /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 /// 26 /// 27 /// 28
2 STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT PURSUANT TO LOCAL RULE 6-1 USDC NDCA Case # CV10-00036 SC
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1

NOW THEREFORE, THE PARTIES HEREBY SUBMIT THIS STIPULATED REQUEST

2 for a Court order extending the deadline for defendant Life Insurance Company of North America to 3 answer or otherwise respond to Plaintiff's complaint by 30 days. 4 5 Date: March 8, 2010 6 7 8 9 10 11 12 13 14 15 16 17 18 19 ORDER Good cause appearing therefore, IT IS HEREBY ORDERED that the deadline for defendant Date: March 8, 2010 WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP By: / S / Adrienne C. Publicover ADRIENNE C. PUBLICOVER SHIVANI NANDA Attorneys for Defendant LIFE INSURANCE COMPANY OF NORTH AMERICA FLYNN, ROSE & PERKINS By: / S / Charles B. Perkins CHARLES B. PERKINS SUSAN PELMULDER Attorneys for Plaintiff DINAH FISCHBACH-BENSON

20 Life Insurance Company of North America to respond to Plaintiff's complaint will be extended to 21 April 5, 2010.
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23 Date: March 8, 2010 24 25 26 27 28

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22 By:

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3 STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT PURSUANT TO LOCAL RULE 6-1 USDC NDCA Case # CV10-00036 SC
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