O'Connell v. UNUM Life Insurance Company of America

Filing 13

STIPULATION AND ORDER re 12 STIPULATION WITH PROPOSED ORDER: Stipulation for Plaintiff to File an Amended Complaint On Or Before May 28, 2014 And The Parties To File Their Joint Case Management Statement On Or Before May 29, 2014 For The June 4, 2014 Conference filed by UNUM Life Insurance Company of America. Amended Pleadings due by 5/28/2014. Case Management Statement due by 5/29/2014. Signed by Judge Jon S. Tigar on May 22, 2014. (wsn, COURT STAFF) (Filed on 5/22/2014)

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RIMAC MARTIN, P.C.
ANNA M. MARTIN SBN 154279
WILLIAM REILLY SBN 177550
1051 Divisadero Street
San Francisco, CA 94115
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
UNUM LIFE INSURANCE COMPANY OF AMERICA

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DAYMON FERGUSON SBN 207053
SPRADLIN & FERGUSON
500 E. Calaveras Blvd. #203
Milpitas, CA 95035
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
LINDA O’CONNELL

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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LINDA O’CONNELL,

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Case No.: 3:14-cv-00869 JST

Plaintiff,

STIPULATION FOR PLAINTIFF TO FILE
AN AMENDED COMPLAINT ON OR
BEFORE MAY 28, 2014 AND THE
PARTIES TO FILE THEIR JOINT CASE
MANAGEMENT STATEMENT ON OR
BEFORE MAY 29, 2014 FOR THE JUNE 4,
2014 CONFERENCE; [PROPOSED]
ORDER

v.
UNUM LIFE INSURANCE COMPANY OF
AMERICA,
Defendant.

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IT IS HEREBY STIPULATED by and between the parties hereto through their
respective attorneys that plaintiff LINDA O’CONNELL will file her amended complaint stating
a single claim for benefits under ERISA, 29 U.S.C. § 1001, et seq. on or before May 28, 2014,
and for the parties to file their Joint Case Management Statement on or before May 29, 2014 for
the June 4, 2014 Case Management Conference.

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STIPULATION FOR PLAINTIFF TO FILE AN AMENDED COMPLAINT ON OR BEFORE
MAY 28, 2014 AND THE PARTIES TO FILE THEIR JOINT CASE MANAGEMENT
STATEMENT ON OR BEFORE MAY 29, 2014 FOR THE JUNE 4, 2014 CONFERENCE
3:14-cv-00869 JST

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GOOD CAUSE exists because plaintiff’s counsel’s mother has recently had a series of
cardiac incidents that required him to spend a lot of time in hospitals.

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RIMAC MARTIN, P.C.

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DATED: May 21, 2014

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LAW OFFICES OF SPRADLIN & FERGUSON

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IT IS SO ORDERED:

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Dated: May 22, 2014
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By: /s/ Daymon M. Ferguson
DAMON M. FERGUSON
Attorney for Plaintiff
ISTR
LINDA O’CONNELL ICT
ES D

__________________________________
ERED
O ORD
HON. JON S TIGAR
IT IS S.

R NIA

DATED: May 21, 2014

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By: /s/ William Reilly
WILLIAM REILLY
Attorneys for Defendant
UNUM LIFE INSURANCE COMPANY OF
AMERICA

UNIT
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STIPULATION FOR PLAINTIFF TO FILE AN AMENDED COMPLAINT ON OR BEFORE
MAY 28, 2014 AND THE PARTIES TO FILE THEIR JOINT CASE MANAGEMENT
STATEMENT ON OR BEFORE MAY 29, 2014 FOR THE JUNE 4, 2014 CONFERENCE
3:14-cv-00869 JST