Ma v. Standard Insurance Company

Filing 5

STIPULATION AND ORDER Extending Time for Defendant to File Initial Responsive Pleading. Signed by Magistrate Judge Howard R. Lloyd on 9/16/05. (hrllc2, COURT STAFF) (Filed on 9/19/2005)

Case 5:05-cv-03634-HRL

Document 5

Filed 09/19/2005

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ANDREW M. ALTSCHUL (#226008) ALTSCHUL LAW OFFICE, PC 117 SW Taylor Street, Suite 200 Portland, Oregon 97204 Telephone: [phone] Facsimile: 503.417.0501 E-mail: [e-mail] Attorney for Defendant DANNING JIANG, ESQ. (#196985) LAW OFFICES OF DANNING JIANG 271 N. First Street San Jose, CA 95113 Telephone: [phone] Facsimile: 408.299.0300 E-mail: [e-mail] Attorney for Plaintiff UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
*E-FILED ON 9/19/05*

MARY JIUYAN MA, Plaintiff, v. STANDARD INSURANCE COMPANY, and DOES ONE TO FIVE, inclusive, Defendants. Case No. C05-03634-HRL STIPULATION ANDXXXXXXXXX [PROPOSED] ORDER TO EXTEND TIME FOR DEFENDANT'S TO FILE INITIAL RESPONSIVE PLEADING

WHEREAS, Defendant Standard Insurance Company ("Defendant") removed this matter to federal court on September 9, 2005 thereby giving Defendant until September 16, 2005 to file its initial responsive pleading; WHEREAS, Defendant would like to discuss with Plaintiff Mary Jiuyan Ma ("Plaintiff") the possibility of voluntarily filing an Amended Complaint to avoid the need for Defendant to file a motion to dismiss based on ERISA preemption; -1STIPULATION AND xxxxxxxxx ORDER TO EXTEND TIME FOR DEFENDANT'S TO FILE INITIAL [PROPOSED] RESPONSIVE PLEADING

Case 5:05-cv-03634-HRL

Document 5

Filed 09/19/2005

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WHEREAS, the parties agree to an extension of time from September 16 to October 14 for Defendant to file its initial responsive pleading or for Plaintiff to file an Amended Complaint; WHEREAS, the agreed upon extension of time will not affect the January 10, 2006 Case Management Conference or any other deadline set by the Court, and good cause exists for entering an order extending the deadline for Defendant to file its initial responsive pleading; IT IS STIPULATED AND AGREED by the parties to extend the time within which Defendant Standard Insurance Co. may plead or otherwise respond to the initial Complaint from September 16, 2005 to October 14, 2005. IT IS SO STIPULATED. DATED: September 15, 2005. ALTSCHUL LAW OFFICE, PC

/s/ Andrew Altschul Andrew M. Altschul (#226008) Attorney for Defendant DATED: September 14, 2005 LAW OFFICES OF DANNING JIANG /s/ Danning Jiang _________________________ Danning Jiang (#196985) Attorney for Plaintiff PURSUANT TO STIPLULATION, IT IS SO ORDERED.

September 16, 2005 DATED:_________________

/s/ Howard R. Lloyd By:________________________________ HON. HOWARD R. LLOYD United States xxxxxxxCourt Judge District xxxx Magistrate

-2STIPULATION ANDxxxxxxxxx ORDER TO EXTEND TIME FOR DEFENDANT'S TO FILE INITIAL [PROPOSED] RESPONSIVE PLEADING