Forest Ambulatory Surigical Associates, L.P. v. United Healthcare Insurance Company

Filing 49

STIPULATION AND ORDER Granting Extending Time to File Second Amended Complaint re 48 Stipulation. Deadline to file Second Amended Complaint due 9/2/2011. Signed by Judge Edward J. Davila on 8/2/2011. (ecg, COURT STAFF) (Filed on 8/2/2011)

HOOPER, LUNDY & BOOKMAN, P.C.

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1875 CENTURY PARK EAST, SUITE 1600
LOS ANGELES, CALIFORNIA 90067-2517
TEL: [phone] • FAX: [phone]

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9 Attorneys for Plaintiff Forest Ambulatory
Surgical Associates, L.P. doing business as Forest
10 Surgery Center

DERED

O OR
IT IS S

NO

5 KATHERINE R. MILLER (State Bar No. 247390)
HOOPER, LUNDY & BOOKMAN, P.C.
6 575 Market Street, Suite 2300
San Francisco, CA 94105
7 Telephone: [phone]
Facsimile: [phone]
[e-mail]
8 E-Mail:

S DISTRICT
TE
C
TA

RT
U
O

1 DARON L. TOOCH (State Bar No. 137269)
HOOPER, LUNDY & BOOKMAN, P.C.
2 1875 Century Park East, Suite 1600
Los Angeles, California 90067-2517
3 Telephone: [phone]
Facsimile: [phone]
[e-mail]
4 E-Mail:

N

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C
OF
D IS T IC T
R
8/2/2011

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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15 FOREST AMBULATORY SURGICAL
ASSOCIATES, L.P., doing business as
16 FOREST SURGERY CENTER,
Plaintiff,

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18

vs.

19 UNITED HEALTHCARE INSURANCE
COMPANY and DOES 1 through 20,
20
Defendants.
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CASE NO. CV10-04911 EJD
(Case Assigned for All Purpose to Hon.
Edward J. Davila)
JOINT STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME TO FILE
SECOND AMENDED COMPLAINT
(Santa Clara Superior Court Number:
110CV183843)
Complaint Filed:

Sept. 29, 2010

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Plaintiff, FOREST AMBULATORY SURGICAL ASSOCIATES (“Forest”) and

24 Defendant, UNITED HEALTHCARE INSURANCE COMPANY (“United”), hereby agree to
25 extend the deadline to file the Second Amended Complaint based on the following reasons:
26

(1)

Forest has requested from United, but not yet received, all of the ERISA

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2037762.1

plan documents and summary plan descriptions for the claims at issue in
this case. The parties anticipate that three additional weeks will provide
CV10-04911 EJD
JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO FILE SECOND AMENDED
COMPLAINT

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[PROPOSED] ORDER

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IT IS HEREBY ORDERED that, good cause having been shown, Forest Ambulatory

4 Surgical Center’s deadline to file its Second Amended Complaint is extended from August 12,
5 2011 to September 2, 2011.
6

IT IS SO ORDERED.

July ___, 2011
7 DATED: August 2, 2011
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9

By:

Honorable Edward J. Davila
United States District Court Judge

HOOPER, LUNDY & BOOKMAN, P.C.

1875 CENTURY PARK EAST, SUITE 1600
LOS ANGELES, CALIFORNIA 90067-2517
TEL: [phone] • FAX: [phone]

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2037762.1

CV10-04911 EJD
JOINT STIPULATION AND [PROPOSED] ORDER EXTENDING TIME TO FILE SECOND AMENDED
COMPLAINT