Peterson v. AT&T Disability Income Plan

Filing 87

STIPULATION AND ORDER TO EXTEND TIME TO FILE MOTION - Until 1/10/12 for Plaintiff to file a motion re: back benefits. Signed by Judge Joseph C. Spero on 12/13/11. (klhS, COURT STAFF) (Filed on 12/13/2011)

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LAFAYETTE & KUMAGAI LLP
SUSAN T. KUMAGAI (State Bar No. 127667)
Email: [e-mail]
REBECCA K. KIMURA (State Bar No. 220420)
Email: [e-mail]
100 Spear Street, Suite 600
San Francisco, California 94105
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
AT&T UMBRELLA BENEFIT PLAN NO. 1

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KANTOR & KANTOR LLP
Glenn R. Kantor (State Bar No. 122643)
Email: [e-mail]
Brent Dorian Brehm (State Bar No. 248923)
Email: [e-mail]
19839 Nordhoff Street
Northridge, California 91324
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff Judi Peterson

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JUDI PETERSON,

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Plaintiff,

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vs.

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Case No. CV 10-3097 JCS
STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME TO FILE
MOTION

AT&T UMBRELLA BENEFIT PLAN
NO. 1,

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Defendant.

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WHEREAS the Court's Findings of Fact and Conclusions of Law was filed in this action
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on November 23, 2011, ordering Plaintiff Judi Peterson ("Plaintiff") and Defendant AT&T
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Umbrella Benefit Plan No. 1 ("Defendant") (collectively, the "Parties") to meet and confer to
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address the amount of back benefits and reasonable attorneys' fees and costs should be awarded
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in this case;
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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE MOTION
(Case No. CV 10-3097 JCS)

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WHEREAS the Court set a deadline of December 14, 2011 for the Parties to reach an

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agreement on these issues, or Plaintiff shall bring a motion setting forth any unresolved issues;

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WHEREAS the Parties have attempted to meet and conferred on these issues, but need

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additional time in order to reach necessary individuals who are not available due to the holidays;

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WHEREAS the Parties request that the Court extend the deadline by which Plaintiff shall

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file a motion regarding unresolved issues to January 10, 2012 so that the Parties can further meet

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and confer;

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IT IS HEREBY STIPULATED BY AND BETWEEN THE PARTIES:

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The last day for Plaintiff to file a motion to resolve issues concerning back benefits,

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attorneys' fees and costs shall be January 10, 2012.

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DATED: December 12, 2011

KANTOR & KANTOR LLP
/s/ Brent Dorian Brehm_______
BRENT DORIAN BREHM
Attorneys for Plaintiff
JUDI PETERSON

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DATED: December 12, 2011

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LAFAYETTE & KUMAGAI LLP
/s/ Rebecca K. Kimura
REBECCA K. KIMURA
Attorneys for Defendant
AT&T UMBRELLA BENEFIT PLAN NO. 1

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[PROPOSED] ORDER

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Pursuant to the Stipulation above, last day for Plaintiff to file a motion to resolve issues
concerning back benefits, attorneys' fees and costs shall be January 10, 2012.

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IT IS SO ORDERED.
December 13, 2011
Dated: ____________________

R NIA

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____________________________________
Spero
HON. JOSEPHseph C. SPERO
Judge Jo C.
United States Magistrate Judge
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D IS T IC T O
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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE MOTION
(Case No. CV 10-3097 JCS)

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CERTIFICATE OF SERVICE

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I certify that a copy of this document was served electronically on December 12, 2011, on
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counsel of record in compliance with Federal Rule 5, Local Rule 5.6 and General Order 45, by
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use of the Court’s ECF system.
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/s/s Rebecca K. Kimura
REBECCA K. KIMURA

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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE MOTION
(Case No. CV 10-3097 JCS)

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