Anderson v. Lawrence Livermmore National Security Health and Welfare Benefit Plan for Employees et al

Filing 24

STIPULATION AND ORDER re 23 STIPULATION WITH PROPOSED ORDER TO EXTEND TIME TO FILE ADMINISTRATIVE RECORD filed by Lawrence Livermmore National Security Health and Welfare Benefit Plan for Employees, Anthem Blue Cross Life and Health Insurance Company. Signed by Judge James Ware on 3/27/12. (sis, COURT STAFF) (Filed on 3/27/2012)

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ER

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Attorneys for Defendants Anthem Blue
Cross Life and Health Insurance Co. and
Lawrence Livermore National Security
Health and Welfare Benefit Plan for
Employees

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Judge Ja

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Kenneth N. Smersfelt (SBN 166764)
[e-mail]
Eric C. Schaffer (SBN 221883)
[e-mail]
Katherine W. Insogna (SBN 266326)
[e-mail]
REED SMITH LLP
355 South Grand Avenue
Suite 2900
Los Angeles, CA 90071
Tel.: [phone]
Fax: [phone]

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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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DENISE ANDERSON,
Plaintiff,

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vs.
LAWRENCE LIVERMORE NATIONAL
SECURITY HEALTH AND WELFARE
BENEFIT PLAN FOR EMPLOYEES;
ANTHEM BLUE CROSS LIFE AND
HEALTH INSURANCE COMPANY,

Case No.: 3:11-cv-03865 JW
JOINT STIPULATION AND
[PROPOSED] ORDER TO
EXTEND TIME TO FILE
ADMINISTRATIVE RECORD

Defendants.

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Case No. 3:11-cv-03865 JW
JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE ADMINISTRATIVE RECORD

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Plaintiff Denise Anderson (“Plaintiff”), Defendant Anthem Blue Cross Life and

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Health Insurance Company (“ABCLH”), and Defendant Lawrence Livermore

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National Security Health and Welfare Benefit Plan for Employees (“Lawrence

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Livermore”) hereby submit, through the undersigned, the following Joint Stipulation

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and [Proposed] Order To Extend Time to File Administrative Record:

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WHEREAS on August 5, 2011, Plaintiff filed her ERISA complaint in the
above-titled action in the United States District Court Northern District of California;

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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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WHEREAS the Court issued a Scheduling Order setting the Deadline for Filing
Administrative Record as March 19, 2012;

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WHEREAS the Parties attended a mediation with Ralph Williams of ADR

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Services and believe they are very close to potentially resolving their dispute and

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agreeing to a settlement;

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WHEREAS the Administrative Record contains confidential medical records

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protected by the Health Insurance Portability and Accountability Act of 1996

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(HIPAA) and the Parties wish to avoid submitting the records, if possible, given the

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potential imminent resolution;

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WHEREAS the Parties wish to continue the Deadline for Filing Administrative

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Record by three weeks to April 9, 2012 to allow the Parties time to potentially reach a

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settlement agreement and dismiss the action; AND

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WHEREAS this change to the Deadline for Filing Administrative Record will
not alter the date of any event or any deadline already fixed by Court order;

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Case No. 3:11-cv-03865 JW
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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE ADMINISTRATIVE RECORD

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IT IS THEREFORE STIPULATED AND AGREED by and between Plaintiff,

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ABCLH, and Lawrence Livermore through the undersigned, to extend the Deadline

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for Filing Administrative Record to April 9, 2012.

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DATED: March 16, 2012.

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LAW OFFICES OF RUSSELL G. PETTI
By

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/s/ Russell G. Petti
Russell G. Petti
Attorneys for Plaintiff Denise Anderson

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REED SMITH LLP

A limited liability partnership formed in the State of Delaware

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DATED: March 16, 2012.

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By

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REED SMITH LLP
/s/ Eric C. Schaffer
Kenneth N. Smersfelt
Eric C. Schaffer
Attorneys for Defendants Anthem Blue
Cross Life and Health Insurance Co. and
Lawrence Livermore National Security
Health and Welfare Benefit Plan for
Employees

PURSUANT TO STIPULATION, IT IS SO ORDERED.
DATE: March 27, 2012

_________________________________
Honorable James Ware

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Case No. 3:11-cv-03865 JW
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JOINT STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE ADMINISTRATIVE RECORD