Bujacich v. Tyler Technologies, Inc. et al

Filing 10

STIPULATION AND ORDER for Continuance of Deadline for Responding to Complaint, signed by Judge Robert J. Bryan. Dfts must file an answer or otherwise respond to the Complaint by 11/19/13.(DK)

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THE HONORABLE ROBERT J. BRYAN

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UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT TACOMA

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NINA J. BUJACICH,

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Plaintiff,
v.
TYLER TECHNOLOGIES, INC., as Plan
Administrator and Sponsor; and TYLER
TECHNOLOGIES SHORT TERM
DISABILITY COVERAGE,
Defendants.

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No. C13-5854-RJB
STIPULATION AND ORDER FOR
CONTINUANCE OF DEADLINE
FOR RESPONDING TO
COMPLAINT
NOTE ON MOTION CALENDAR:
MONDAY, OCTOBER 28, 2013

STIPULATION

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Plaintiff Nina Bujacich (“Plaintiff”) and Defendants Tyler Technologies, Inc. (“Tyler”)

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and Tyler Technologies Short Term Disability Coverage (the “Plan”) (collectively

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“Defendants”), hereby stipulate to a brief extension of Defendants’ deadline to answer or

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otherwise respond to Plaintiff’s Complaint.

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The parties have good reason to request a brief extension pursuant to Western District

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Local Rule CR 10(g) for the following reason: In an effort to explore a potential resolution of

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this matter without involving the Court and without engaging in the additional expense of

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drafting pleadings or motions, the parties have agreed to participate in early settlement

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negotiations. To facilitate these discussions, the parties find it necessary to request a brief

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extension of the responsive deadline, as follows:
STIPULATION AND ORDER- 1
No. C13-5854-RJB
121731.0002/5861876.1

LANE POWELL PC
1420 FIFTH AVENUE, SUITE 4100
SEATTLE, WASHINGTON 98101-2338
206.223.7000 FAX: [phone]

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CURRENT SCHEDULE
Defendants must file an answer or otherwise
respond to the Complaint by: October 29,
2013

PROPOSED REVISED SCHEDULE
Defendants must file an answer or otherwise
respond to the Complaint by: November 19,
2013

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No scheduling order has been entered and the brief extension will not impact the
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efficient proceeding of this litigation should a resolution not be reached.
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DATED this 28th day of October, 2013.
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LANE POWELL PC

TODD R. RENDA, ATTORNEY AT LAW

By s/Sarah E. Swale
Sarah E. Swale, WSBA No. 29626
Kelly M. Turner, WSBA No. 43022
Attorneys for Defendants

By s/Todd R. Renda
Todd R. Renda, WSBA No. 13542
Attorneys for Plaintiff

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ORDER
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IT IS SO ORDERED.
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DATED this 30th day of October, 2013.

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ROBERT J. BRYAN
United States District Judge

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PRESENTED BY:

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LANE POWELL PC

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By s/Sarah E. Swale
Sarah E. Swale, WSBA No. 29626
Kelly M. Turner, WSBA No. 43022
Attorneys for Defendants

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STIPULATION AND ORDER- 2
No. C13-5854-RJB
121731.0002/5861876.1

LANE POWELL PC
1420 FIFTH AVENUE, SUITE 4100
SEATTLE, WASHINGTON 98101-2338
206.223.7000 FAX: [phone]

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APPROVED; NOTICE OF PRESENTATION WAIVED:

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TODD R. RENDA, ATTORNEY AT LAW

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By s/Todd R. Renda
Todd R. Renda, WSBA No. 20779
Attorney for Plaintiff

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STIPULATION AND ORDER- 3
No. C13-5854-RJB
121731.0002/5861876.1

LANE POWELL PC
1420 FIFTH AVENUE, SUITE 4100
SEATTLE, WASHINGTON 98101-2338
206.223.7000 FAX: [phone]

CERTIFICATE OF SERVICE

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Pursuant to RCW 9.A.72.085, the undersigned certifies under penalty of perjury under

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the laws of the State of Washington and the United States, that on the 28th day of October,

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2013, the document attached hereto was presented to the Clerk of the Court for filing and

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uploading to the CM/ECF system. In accordance with their ECF registration agreement and the

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Court’s rules, the Clerk of the Court will send e-mail notification of such filing to the

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following:

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Todd R. Renda
Attorney at Law
6314 19th Street West, Suite 21
Tacoma, WA 98466-6233
Email: [e-mail]

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DATED this 28th day of October, 2013, at Seattle, Washington.

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s/ Lorrie A. Salinas
Lorrie A. Salinas

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STIPULATION AND ORDER- 4
No. C13-5854-RJB
121731.0002/5861876.1

LANE POWELL PC
1420 FIFTH AVENUE, SUITE 4100
SEATTLE, WASHINGTON 98101-2338
206.223.7000 FAX: [phone]