Haddad v. Monumental Life Insurance Company

Filing 10

STIPULATION AND ORDER re 5 STIPULATION WITH PROPOSED ORDER TO FILE AN AMENDED COMPLAINT AND EXTEND DEFENDANT'S TIME TO RESPOND filed by Monumental Life Insurance Company. Signed by Judge Edward M. Chen on 5/2/13. (bpf, COURT STAFF) (Filed on 5/2/2013)

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KURT R. BOCKES, Bar No. 171647
ANGELA J. RAFOTH, Bar No. 241966
LITTLER MENDELSON
A Professional Corporation
650 California Street, 20th Floor
San Francisco, CA 94108.2693
Telephone:
415.433.1940
Facsimile:
415.399.8490
E-mail: [e-mail]
[e-mail]
Attorneys for Defendant
MONUMENTAL LIFE INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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JOSEPH HADDAD,
Plaintiff,

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v.
MONUMENTAL LIFE INSURANCE
COMPANY,

Case No. CV 13 1636 JSC
STIPULATION AND [PROPOSED] ORDER
TO FILE AN AMENDED COMPLAINT
AND EXTEND DEFENDANT’S TIME TO
RESPOND

Defendant.

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Plaintiff Joseph Haddad (“Plaintiff”) and Defendant Monumental Life Insurance Company
(“Defendant”), through their respective counsel, stipulate as follows:
WHEREAS Plaintiff, a former employee of Defendant, filed a Complaint against Defendant
in this Court on April 10, 2013;
WHEREAS the parties have conferred regarding the causes of action alleged in Plaintiff’s
complaint in an effort to avoid unnecessary motion practice;
WHEREAS Plaintiff wishes to file an Amended Complaint;

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LITTLER MENDELSON, P.C.
650 California Street
20th Floor
San Francisco, CA 94108.2693
415.433.1940

STIP. RE AMENDED COMPLAINT

Case No. CV 13 1636 JSC

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WHEREAS the parties agree that it would be inefficient for the parties and the Court for

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Defendant to respond to the initial Complaint, which response is currently due May 9, 2013, and

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have Plaintiff file an Amended Complaint mere days later.

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IT IS HEREBY STIPULATED AND AGREED, by and through the parties’ respective
counsel of record, as follows:

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1.

Defendant’s time to respond to Plaintiff’s Complaint is extended to May 17, 2013;

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2.

Plaintiff may file an Amended Complaint on or before May 10, 2013;

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3.

In the event Plaintiff files an Amended Complaint, Defendant shall have until

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May 31, 2013, to answer or otherwise respond to Plaintiff’s Amended Complaint.
IT IS SO STIPULATED.

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Dated: May 1, 2013

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/s/ Kurt R. Bockes
KURT R. BOCKES
LITTLER MENDELSON
A Professional Corporation
Attorneys for Defendant
MONUMENTAL LIFE INSURANCE COMPANY

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Dated: May 1, 2013
/s/ Frear Stephen Schmid
FREAR STEPHEN SCHMID
LAW OFFICES OF GARY A. ANGEL
Attorneys for Plaintiff
JOSEPH HADDAD

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S

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RT

Firmwide:119795452.3 071786.1001

LITTLER MENDELSON, P.C.
650 California Street
20th Floor
San Francisco, CA 94108.2693
415.433.1940

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STIP. RE AMENDED COMPLAINT

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M. Che

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dward
Judge E

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RDERE
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U.S. DISTRICT COURT JUDGE

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5/2
Dated: _________, 2013

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PURSUANT TO STIPULATION AND GOOD CAUSE APPEARING, IT IS SO ORDERED:

UNIT
ED

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Case No. CV 13 1636 JSC
OF

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