Ramos v. Bank of America et al

Filing 25

STIPULATION AND ORDER TO EXTEND TIME TO FILE MOTION TO COMPEL re 24 Stipulation filed by Metropolitan Life Insurance Company. Signed by Judge Phyllis J. Hamilton on 9/30/08. (nah, COURT STAFF) (Filed on 9/30/2008)

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SEDGWICK, DETERT, MORAN & ARNOLD LLP REBECCA A. HULL Bar No. 99802 MICHELLE Y. MCISAAC Bar No. 215294 One Market Plaza Steuart Tower, 8th Floor San Francisco, California 94105 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants Metropolitan Life Insurance Company and Bank of America Long Term Disability Benefits Plan (erroneously sued as Bank of America Long Term Disability Plan) UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA LENA MONZON RAMOS, Plaintiff, v. BANK OF AMERICA; METROPOLITAN LIFE INSURANCE COMPANY; BANK OF AMERICA LONG TERM DISABILITY PLAN, Defendants. CASE NO. CV 08-01375 PJH STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE MOTION TO COMPEL

Defendants Metropolitan Life Insurance Company ("MetLife") and Bank of America Long Term Disability Benefits Plan ("defendants" herein) and plaintiff Lena Monzon Ramos, by and through their attorneys of record, hereby agree and stipulate as follows: 1. On July 31, 2008, this Court held a Case Management Conference in which the

Court ordered that the parties would have sixty (60) days to file a motion to compel discovery, that is, on or before September 29, 2008; 2. Following discussions between plaintiff and defendants regarding discovery

issues, plaintiff served her first set of interrogatories and her first set of requests for production of documents on MetLife, on August 29, 2008. MetLife's responses to plaintiff's discovery currently are due September 30, 2008;
-1CASE NO. CV 08-01375 PJH STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME TO FILE MOTION TO COMPEL

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3.

The parties have stipulated that plaintiff may have an extension, until October 28,

2008, in which to file any motions to compel discovery in this action, and request that the Court so order. IT IS SO STIPULATED. DATED: September 30, 2008 SEDGWICK, DETERT, MORAN & ARNOLD LLP

By:

/s/ Michelle Y. McIsaac Rebecca A. Hull Michelle Y. McIsaac Attorneys for Defendants Metropolitan Life Insurance Company and Bank of America Long Term Disability Benefits Plan

DATED: September __, 2008

THE LAW OFFICE OF JOSEPH CREITZ, P.C.

By:

Joseph Creitz Attorney for Plaintiff Lena Monzon Ramos ORDER

Upon the stipulation of the parties, IT IS SO ORDERED. DATED: 9/30/08

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