Wong v. Walgreen Income Protection Plan for Store Managers

Filing 8

STIPULATION AND ORDER EXTENDING TIME TO FOLLOW RESPONSIVE PLEADING. Signed by Magistrate Judge Maria-Elena James on 6/20/2013. (rmm2S, COURT STAFF) (Filed on 6/20/2013)

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Robert J. Rosati, State Bar No. 112006
Thornton Davidson, State Bar No. 166487
ERISA Law Group LLP
2055 San Joaquin Street
Fresno, CA 93721
[phone] – Tel
[phone] – Fax

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Attorneys for Defendant
Walgreen Income Protection Plan
for Store Managers

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6/20/2013

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Dated:

400 Capitol Mall, 11th Floor
Sacramento, CA 95814
[phone] – Main
[phone] – Facsimile

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a law corporation

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Scott M. Plamondon, State Bar No. 212294
Brendan J. Begley, State Bar No. 202563
weintraub tobin chediak coleman grodin

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Attorneys for Plaintiff
VANESSA WONG

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO

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Plaintiff,

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) Case No. CV 13 1884 MEJ
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) SECOND STIPULATION TO EXTEND TIME
) TO FILE RESPONSIVE PLEADING
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VANESSA WONG,

vs.
WALGREEN INCOME PROTECTION
PLAN FOR STORE MANAGERS,
Defendant.

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Pursuant to Local Rule 6-1 of the United States District Court for the Northern District of

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California, Defendant Walgreen Income Protection Plan for Store Managers (“Defendant”) and

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Plaintiff Vanessa Wong, by and through their respective attorneys of record, hereby stipulate and

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agree as follows:

{1646831.DOC;}

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Second Stip. to Extend Time to File Resp. Pleading

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1.

On May 9, 2013, Defendant was served with Plaintiff’s Complaint alleging denial

of disability benefits in violation of the Employment Retirement Income Security Act.
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On May 22, 2013, counsel of record for Defendant and counsel of record for

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Plaintiff agreed to a twenty-one (21) day extension of time for Defendant to file a pleading in

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response to the Complaint.

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3.

On June 19, 2013, counsel of record for Defendant and counsel of record for

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Plaintiff agreed to a seven (7) day extension of time for Defendant to file a pleading in response

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to the Complaint.

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4.

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June 27, 2013.

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4.

Defendant will file a pleading in response to Plaintiff’s Complaint on or before

This Stipulation to Extend Time to File Responsive Pleading will not alter the date

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of any event or any deadline fixed by this Court as no such date of any event or deadline has

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been fixed by this Court.

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Dated: June 19, 2013

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Respectfully submitted,

weintraub tobin chediak coleman grodin

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a law corporation

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By:

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/s/ Brendan J. Begley
Scott M. Plamondon
Brendan J. Begley
Attorneys for Defendant Walgreen Co.

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Dated: June 19, 2013

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ERISA Law Group LLP

By:

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/s/ Robert J. Rosati (approved on 6/19/13)
Robert J. Rosati
Thornton Davidson
Attorneys for Plaintiff Vanessa Wong

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{1646831.DOC;}

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Second Stip. to Extend Time to File Resp. Pleading