Facen v. Boston Mutual Life Insurance Company

Filing 8

STIPULATION AND ORDER EXTENDING TIME TO ANSWER re 7 Stipulation filed by Boston Mutual Life Insurance Company. Signed by Judge Edward M. Chen on 2/25/11. (bpf, COURT STAFF) (Filed on 2/25/2011)

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

RIMAC MARTIN, P.C. ANNA M. MARTIN - State Bar No. 154279 MATTHEW HICKEY - State Bar No. 239364 1051 Divisadero Street San Francisco, California 94115 Telephone [phone] Facsimile [phone] [e-mail] Attorneys for Defendant BOSTON MUTUAL LIFE INSURANCE COMPANY LAW OFFICES OF P. RANDALL NOAH P. Randall Noah - State Bar No. 136452 21 Orinda Way, Suite C, #316 Orinda, CA 94563 Telephone [phone] Facsimile [phone] [e-mail] Attorney for Plaintiff LISA FACEN

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA (San Jose Division)
LISA FACEN, ) ) Plaintiff, ) ) vs. ) ) BOSTON MUTUAL LIFE INSURANCE ) COMPANY, ) ) Defendant. ) ) ______________________________________ )

17 18 19 20 21 22 23 24 25 26 27 28

CASE NO. C11-00453 EMC STIPULATION EXTENDING TIME FOR BOSTON MUTUAL LIFE INSURANCE TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT ; ORDER

IT IS HEREBY STIPULATED that defendant BOSTON MUTUAL LIFE INSURANCE COMPANY (hereinafter "Boston Mutual") may have an extension to answer or otherwise respond to plaintiff's complaint, such that Boston Mutual's response is now due on or before March 8, 2011.

-1FACEN v. BOSTON MUTUAL LIFE INS. STIPULATION TO EXTEND TIME TO ANSWER CASE NO.: C11-00453 EMC

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15

Good cause exists for this extension because lead counsel for Boston Mutual is presently involved in numerous matters with impending trial dates, and due to the unusually heavy case load requires this additional time to fully evaluate this matter. Pursuant to local rules, this document is being electronically filed through the Court's ECF System. In this regard, counsel for defendant hereby attests that (1) the content of this document is acceptable to all persons required to sign the document; (2) plaintiff's counsel has concurred with the filing of this document; and (3) a record supporting this concurrence is available for inspection or production if so ordered. SO STIPULATED.

DATED: February 24, 2011

By: /s/ Anna M. Martin ANNA M. MARTIN MATTHEW HICKEY Attorneys for Defendants BOSTON MUTUAL LIFE INSURANCE CO.

DATED: February 24, 2011 16 17 18 19 20 21 22 23 24 25 26 27 28 IT IS SO ORDERED:
UNIT ED

By: /s/ Randall Noah RANDALL NOAH Attorney for Plaintiff LISA FACEN

S

S DISTRICT TE C TA

ER

N

F D IS T IC T O R

A

C

FACEN v. BOSTON MUTUAL LIFE INS. STIPULATION TO EXTEND TIME TO ANSWER

LI

FO

Judge E

dward M

. Chen

R NIA

________________ Edward M. Chen U.S. Magistrate Judge

IT IS S

O ORD

ERED

RT U O

NO

RT

H

-2CASE NO.: C11-00453 EMC

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

PROOF OF SERVICE LISA FACEN v. BOSTON MUTUAL LIFE INSURANCE COMPANY USDC Northern District of CA (Oakland Division) Case No.: C11-00453 EMC I am employed at Rimac Martin, P.C., 1051 Divisadero Street, San Francisco, California 94115. I am over the age of 18 years and am not a party to this action. On this date I served the following: STIPULATION TO EXTEND TIME FOR BOSTON MUTUAL LIFE INSURANCE TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT on the interested parties hereto by the following method:

XXX VIA CM/ECF SYSTEM ELECTRONIC SERVICE: I certify that a true and accurate copy of the above-mentioned document was filed with the Clerk of the Court using the CM/ECF Filing System. I am informed and believe that the document(s) will be electronically served on the following attorney(s) of record at the listed email addressed below. [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail]; [e-mail] I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed February 25, 2011, at San Francisco, California. /s/ Kim N. Phan Kim N. Phan

-3FACEN v. BOSTON MUTUAL LIFE INS. STIPULATION TO EXTEND TIME TO ANSWER CASE NO.: C11-00453 EMC