Seton Medical Center v. Blue Cross and Blue Shield of North Carolina

Filing 12

ORDER GRANTING re 11 Stipulation to Extend Defendant's Time to Answer, Move or Otherwise Respond to Plaintiff's Complaint filed by Blue Cross and Blue Shield of North Carolina. Signed by Chief Magistrate Judge Joseph C. Spero on 1/27/16. (klhS, COURT STAFF) (Filed on 1/27/2016)

1 William E. von Behren, State Bar No. 106642
[e-mail]
2 Joann V. Lee, State Bar No. 251653
[e-mail]
3 VON BEHREN & HUNTER LLP
2041 Rosecrans Avenue, Suite 367
4 El Segundo, CA 90245
Telephone: [phone]
5 Facsimile: [phone]
6 Attorneys for Defendant
BLUE CROSS AND BLUE SHIELD OF NORTH
7 CAROLINA

& HUNTER LLP
VON BEHREN

UNITED STATES DISTRICT COURT

9

2 0 4 1 R O S E C R A N S AVENUE
EL SEGUNDO, CALIF ORNIA 902 45

8

NORTHERN DISTRICT OF CALIFORNIA

10 SETON MEDICAL CENTER, a California
non-profit religious corporation,
11
Plaintiff,
vs.
12
13 BLUE CROSS AND BLUE SHIELD OF
NORTH CAROLINA, a North Carolina
14 non-profit corporation; and DOES 1
THROUGH 25, INCLUSIVE,
15
Defendants.
16
17

Case No. 15-cv-06254-JCS
STIPULATION TO EXTEND
DEFENDANT BLUE CROSS AND BLUE
SHIELD OF NORTH CAROLINA’S
TIME TO ANSWER, MOVE OR
OTHERWISE RESPOND TO
PLAINTIFF’S COMPLAINT

Pursuant to Civil Local Rule 6-1(a), Plaintiff, Seton Medical Center (“Plaintiff”),

18 and Defendant Blue Cross and Blue Shield of North Carolina (“BCBSNC”), by and through
19 their respective counsel of record, hereby stipulate as follows:
20

Plaintiff served its state court Complaint on November 25, 2015;

21

BCBSNC removed this civil action, Case No. CIV536368, from the Superior Court

22 of the State of California, for the County of San Mateo, to the United States District Court,
23 for the Northern District of California, based upon diversity on December 29, 2015;
24

A responsive pleading to the Complaint was due to be filed and served on behalf of

25 BCBSNC on or before January 5, 2016;
26

The parties stipulated to, and the Court granted, an extension of time of an additional

27 27 days to and including February 1, 2016 for BCBSNC to answer, move or otherwise
28 respond to the Complaint;
-1-

1

The parties are engaged in settlement negotiation and in order to facilitate further

2 settlement discussions, BCBSNC has requested and Plaintiff has granted an additional 30
3 days to and including March 1, 2016 for BCBSNC to answer, move or otherwise respond to
4 the Complaint;
5

The next Court ordered deadline is on March 11, 2016 for the parties to meet and

6 confer re initial disclosures and early settlement. An additional 30 days for BCBSNC to
7 answer or respond to Plaintiff’s Complaint will not alter the date of any event or any
8 deadline already fixed by Court order;
9

Therefore, IT IS HEREBY STIPULATED by and between Plaintiff and BCBSNC,

10 by and through their respective attorneys of record, that BCBSNC shall answer, move or

12
13 Dated: January 26, 2016

STEPHENSON, ACQUISTO & COLMAN
Melanie Joy Stephenson
Barry Sullivan
Richard A. Lovich
Karlene J. Rogers Aberman
Christine V. Nitoff

14
15
16
17

By:

/s/ Christine V. Nitoff
Christine V. Nitoff
Attorneys for Plaintiff
SETON MEDICAL CENTER

18
19
20
21

Dated: January 26, 2016

VON BEHREN & HUNTER LLP
William E. von Behren
Joann Lee

22
23
24

Spero

RT
H

ER

R NIA

Judge Jo

FO

seph C.

NO

28

Dated: January 27, 2016

LI

27

ERED
O ORD

IT IS S

A

26

By: /s/ Joann Lee
Joann Lee
ISTRIC
Attorneys for Defendant
ES D
TC
T
BLUE CROSS AND BLUE SHIELD
TA
OF NORTH CAROLINA
RT
U
O

S

25
UNIT
ED

& HUNTER LLP
VON BEHREN

2 0 4 1 R O S E C R A N S AVENUE
EL SEGUNDO, CALIF ORNIA 902 45

11 otherwise respond to Plaintiff’s Complaint on or before March 1, 2016.

N

- 2C -

F
D IS T IC T O
R