Yoon v. First Unum Life Insurance Company et al

Filing 28

STIPULATION AND ORDER EXTENDING PLAINTIFF'S TIME TO FILE FIRST AMENDED COMPLAINT re 27 Proposed Order filed by Daniel Dong Yul Yoon. Signed by Judge Phyllis J. Hamilton on 10/19/09. (nah, COURT STAFF) (Filed on 10/19/2009)

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E. Gerard Mannion (State Bar #77287)
E -m a i l: g m a n n io n @ s b c g lo b a l.n e t

Wesley M. Lowe (State Bar #111761)
E -m a i l: w lo w e @ s b c g lo b a l.n e t

Demián I. Oksenendler (State Bar #233416)
E -m a i l: d o k se n e n d le r @ s b c g lo b a l.n e t

MANNION & LOWE 655 Montgomery Street, Suite 1200 San Francisco, California 94111 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff, DANIEL YOON

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA - OAKLAND DIVISION

DANIEL (DONG YUL) YOON, Plaintiff, vs. FIRST UNUM LIFE INSURANCE COMPANY, UNUM PROVIDENT CORPORATION, UNUM GROUP, INC, and DOES 1 through 30, inclusive, Defendants.

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Case No.:

C 09-2529 PJH

STIPULATION EXTENDING PLAINTIFF'S TIME TO FILE FIRST AMENDED COMPLAINT [PROPOSED] ORDER

The parties to the above-captioned case are requesting the Court grant an additional 30-day extension of time for plaintiff to file his first amended complaint. Plaintiff's last day to file the first amended complaint is presently October 17, 2009. This would extend his last day to file the first amended complaint until November 16, 2009. Plaintiff has requested this extension in order to provide defendants with new medical information, records, studies, and reports related to the medical condition at issue in this case. Plaintiff will be asking defendants to reconsider their decision to terminate his benefits based upon this new information. It is taking longer than plaintiff had hoped to assemble the information in part because some of it is coming from Canadian medical providers, some of whom have not been 1
S t ip u la tio n Extending Plaintiff's Time to File First Amended Complaint C a s e No.: C 09-2529 PJH

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moving as promptly as plaintiff would like. Once the information is obtained, the defendants will then be presented with it. The defendants' response to the information and request for reconsideration may affect what issues are presented in the first amended complaint. This extension will give the parties time to complete these activities before the first amended complaint needs to be filed. The Court is therefore requested to grant the extension agreed to by the parties.

Dated: October 16, 2009

MANNION & LOWE A Professional Corporation By: /s/ E. Gerard Mannion Attorneys for Plaintiff, DANIEL (DONG YUL) YOON

Dated: October 16, 2009 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
G : \ M a i n G r o u p \ C l i e n t s \ Y o o n v . U N U M \ P l e a d i n g s \ S t i p to E x t e n d 9 - 3 - 0 9 . w p d

RIMAC MARTIN, P.C. By: /s/ Anna M. Martin Attorneys for Defendants FIRST UNUM LIFE INSURANCE CO., UNUM PROVIDENT CORP., and UNUM GROUP, INC.

IT IS SO ORDERED.

UNIT ED

10/19/09

_______________________________ Hon. Phyllis Jean Hamilton

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S t ip u la tio n Extending Plaintiff's Time to File First Amended Complaint C a s e No.: C 09-2529 PJH

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