Jacobs v. Life Insurance Company of North America et al

Filing 11

ORDER to extend tiem to answer re 10 Stipulation filed by United Airlines Long Term Disability Plan, Life Insurance Company of North America. Signed by Judge Charles R. Breyer on 12/29/2011. (beS, COURT STAFF) (Filed on 1/3/2012)

Case3:11-cv-05418-CRB Document10 Filed12/22/11 Page1 of 4

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ADRIENNE C. PUBLICOVER (SBN: 161432)
Email: [e-mail]
CHARAN M. HIGBEE (SBN: 148293)
Email. [e-mail]
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
525 Market Street, 17th Floor
San Francisco, CA 94105
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendants
LIFE INSURANCE COMPANY OF NORTH AMERICA
and UNITED AIRLINES EMPLOYEE WELFARE
BENEFIT PLAN (sued herein as “UNITED AIRLINES
LONG TERM DISABILITY PLAN”)

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TERESA RENAKER (SBN: 187800)
Email: [e-mail]
NINA WASOW (SBN: 242047)
Email: [e-mail]
LEWIS, FEINBERG, LEE, RENAKER & JACKSON, P.C.
476 – 9th Street
Oakland, CA 94607
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Plaintiff
DEBORAH JACOBS

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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DEBORAH JACOBS,

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Case No.: C11-05418-CRB

Plaintiff,
v.
LIFE INSURANCE COMPANY OF NORTH
AMERICA and UNITED AIRLINES LONG
TERM DISABILITY PLAN,
Defendants.

SECOND STIPULATION TO EXTEND
TIME TO ANSWER OR OTHERWISE
RESPOND TO PLAINTIFF’S
COMPLAINT; AND [PROPOSED]
ORDER
Action Filed: November 8, 2011
Trial Date: None

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SECOND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT AND [PROPOSED] ORDER
810785.1
USDC NDCA Case No. C11-05418-CRB

Case3:11-cv-05418-CRB Document10 Filed12/22/11 Page2 of 4

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IT IS HEREBY STIPULATED, pursuant to Local Rules 6-1 and 6-2, by and between

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plaintiff Deborah Jacobs and defendants Life Insurance Company of North America (“LINA”)

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and United Airlines Employee Welfare Benefit Plan (sued herein as “United Airlines Long Term

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Disability Plan”), through their attorneys of record, as follows:
1.

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Defendants LINA and United Airlines Employee Welfare Benefit Plan were

served with the Summons and Complaint in this action on November 10, 2011;
2.

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The parties to this action initially agreed that Defendants LINA and United

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Airlines Employee Welfare Benefit Plan would have an extension to and including December

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30, 2011 to answer or otherwise respond to the Complaint filed in this action;
3.

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A Stipulation To Extend Time To Answer Or Otherwise Respond To Plaintiff’s

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Complaint, granting the defendants an extension to December 30, 2011, was filed in this action

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on November 22, 2011;
4.

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Defendants need additional time to prepare their Answer to the Complaint.

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During the week of December 26, 2011, Charan M. Higbee, attorney for the defendants, will be

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on vacation. During this same week, client representatives of both defendants also are on

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vacation. For this reason, defendants and their attorneys will not be able to finalize the Answer

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during the week of December 26, 2011.
5.

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The parties to this action have agreed that Defendants LINA and United Airlines

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Employee Welfare Benefit Plan may have an extension to an including January 6, 2012 to

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answer or otherwise respond to the Complaint filed in this action; and
6.

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This extension of time to respond to the Complaint does not alter the date of any

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event or any deadline already fixed by Court Order.

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SECOND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT AND [PROPOSED] ORDER
810785.1
USDC NDCA Case No. C11-05418-CRB

Case3:11-cv-05418-CRB Document10 Filed12/22/11 Page3 of 4
Date: December 22, 2011

WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP

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By:

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/s/ Charan M. Higbee
ADRIENNE C. PUBLICOVER
CHARAN M. HIGBEE
Attorneys for Defendants
LIFE INSURANCE COMPANY OF NORTH
AMERICA and UNITED AIRLINES
EMPLOYEE WELFARE BENEFIT PLAN (sued
herein as “UNITED AIRLINES LONG TERM
DISABILITY PLAN”)

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Date: December 22, 2011

LEWIS, FEINBERG, LEE, RENAKER
& JACKSON, P.C.

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By:
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_/s/ Nina Wasow_____________
TERESA RENAKER
NINA WASOW
Attorneys for Plaintiff
DEBORAH JACOBS

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ORDER

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PURSUANT TO STIPULATION, IT IS HEREBY ORDERED:

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Defendants Life Insurance Company of North America and United Airlines Employee

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Welfare Benefit Plan (sued as “United Airlines Long Term Disability Plan”) have an extension

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to and including January 6, 2012 to answer or otherwise respond to plaintiff’s Complaint in this

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action.

S

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IT IS S

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R NIA

HONORABLE CHARLES R. BREYER
ED
UNITED STATES DISTRICT COURT JUDGE
ORDER

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By:

UNIT
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Date: December 29, 2011
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SECOND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT AND [PROPOSED] ORDER
810785.1
USDC NDCA Case No. C11-05418-CRB

Case3:11-cv-05418-CRB Document10 Filed12/22/11 Page4 of 4

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CERTIFICATE OF SERVICE

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Jacobs v. Life Insurance Company of North America, et al.
U.S.D.C. Northern District of California Case No.: C11-05418-CRB

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At the time of service I was over 18 years of age and not a party to this action. I am
employed by WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP. My business
address is 525 Market Street, 17th Floor, San Francisco, California 94105. My business
telephone number is [phone]; my business fax number is [phone]. On this date I
served the following document(s):

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SECOND STIPULATION TO EXTEND TIME TO ANSWER OR OTHERWISE
RESPOND TO PLAINTIFF’S COMPLAINT
AND [PROPOSED] ORDER

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on the person or persons listed below, through their respective attorneys of record in this action,
by placing true copies thereof in sealed envelopes or packages addressed as shown below by the
following means of service:

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:
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By Electronic Service. Based on a court order or an agreement of the parties to accept
service by electronic transmission, I caused the documents to be sent to the persons at the
electronic notification addresses listed below.

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Teresa Renaker
Nina Wasow
Lewis, Feinberg, Lee, Renaker & Jackson, P.C.
476-9th Street
Oakland, CA 94607
Ph: 510.839.6824
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff, Deborah Jacobs

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I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct to the best of my knowledge.
EXECUTED on December 22, 2011 at San Francisco, California.

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/s/ Monique Jacquis
Monique Jacquis

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SECOND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT AND [PROPOSED] ORDER
810785.1
USDC NDCA Case No. C11-05418-CRB