Opinion
Case No.: C11-05418-CRB
11-08-2011
DEBORAH JACOBS, Plaintiff, v. LIFE INSURANCE COMPANY OF NORTH AMERICA and UNITED AIRLINES LONG TERM DISABILITY PLAN, Defendants.
ADRIENNE C. PUBLICOVER (SBN: 161432) CHARAN M. HIGBEE (SBN: 148293) WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP Attorneys for Defendants LIFE INSURANCE COMPANY OF NORTH AMERICA and UNITED AIRLINES EMPLOYEE WELFARE BENEFIT PLAN (sued herein as "UNITED AIRLINES LONG TERM DISABILITY PLAN") TERESA RENAKER (SBN: 187800) NINA WASOW (SBN: 242047) LEWIS, FEINBERG, LEE, RENAKER & JACKSON, P.C. Attorneys for Plaintiff DEBORAH JACOBS
ADRIENNE C. PUBLICOVER (SBN: 161432)
CHARAN M. HIGBEE (SBN: 148293)
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
Attorneys for Defendants
LIFE INSURANCE COMPANY OF NORTH AMERICA
and UNITED AIRLINES EMPLOYEE WELFARE
BENEFIT PLAN (sued herein as "UNITED AIRLINES
LONG TERM DISABILITY PLAN")
TERESA RENAKER (SBN: 187800)
NINA WASOW (SBN: 242047)
LEWIS, FEINBERG, LEE, RENAKER & JACKSON, P.C.
Attorneys for Plaintiff
DEBORAH JACOBS
SECOND STIPULATION TO EXTEND TIME TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT; AND [PROPOSED] ORDER
Trial Date: None
IT IS HEREBY STIPULATED, pursuant to Local Rules 6-1 and 6-2, by and between plaintiff Deborah Jacobs and defendants Life Insurance Company of North America ("LINA") and United Airlines Employee Welfare Benefit Plan (sued herein as "United Airlines Long Term Disability Plan"), through their attorneys of record, as follows:
1. Defendants LINA and United Airlines Employee Welfare Benefit Plan were served with the Summons and Complaint in this action on November 10, 2011;
2. The parties to this action initially agreed that Defendants LINA and United Airlines Employee Welfare Benefit Plan would have an extension to and including December 30, 2011 to answer or otherwise respond to the Complaint filed in this action;
3. A Stipulation To Extend Time To Answer Or Otherwise Respond To Plaintiff's Complaint, granting the defendants an extension to December 30, 2011, was filed in this action on November 22, 2011;
4. Defendants need additional time to prepare their Answer to the Complaint. During the week of December 26, 2011, Charan M. Higbee, attorney for the defendants, will be on vacation. During this same week, client representatives of both defendants also are on vacation. For this reason, defendants and their attorneys will not be able to finalize the Answer during the week of December 26, 2011.
5. The parties to this action have agreed that Defendants LINA and United Airlines Employee Welfare Benefit Plan may have an extension to an including January 6, 2012 to answer or otherwise respond to the Complaint filed in this action; and
6. This extension of time to respond to the Complaint does not alter the date of any event or any deadline already fixed by Court Order.
___________________________
WILSON, ELSER, MOSKOWITZ,
EDELMAN & DICKER LLP
By: ___________________________
ADRIENNE C. PUBLICOVER
CHARAN M. HIGBEE
Attorneys for Defendants
LIFE INSURANCE COMPANY OF NORTH
AMERICA and UNITED AIRLINES
EMPLOYEE WELFARE BENEFIT PLAN (sued
herein as "UNITED AIRLINES LONG TERM
DISABILITY PLAN")
LEWIS, FEINBERG, LEE, RENAKER
& JACKSON, P.C.
By: ___________________________
TERESA RENAKER
NINA WASOW
Attorneys for Plaintiff
DEBORAH JACOBS
ORDER
PURSUANT TO STIPULATION, IT IS HEREBY ORDERED:
Defendants Life Insurance Company of North America and United Airlines Employee Welfare Benefit Plan (sued as "United Airlines Long Term Disability Plan") have an extension to and including January 6, 2012 to answer or otherwise respond to plaintiff's Complaint in this action.
By: ___________________________
HONORABLE CHARLES R. BREYER
UNITED STATES DISTRICT CUORT
CERTIFICATE OF SERVICE
Jacobs v. Life Insurance Company of North America, et al.
U.S.D.C. Northern District of California Case No.: C11-05418-CRB
At the time of service I was over 18 years of age and not a party to this action. I am employed by WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP. My business address is 525 Market Street, 17 Floor, San Francisco, California 94105. My business telephone number is (415) 433-0990; my business fax number is (415) 434-1370. On this date I served the following document(s):
SECOND STIPULATION TO EXTEND TIME TO ANSWER OR OTHERWISE
RESPOND TO PLAINTIFF'S COMPLAINT
AND [PROPOSED] ORDER
on the person or persons listed below, through their respective attorneys of record in this action, by placing true copies thereof in sealed envelopes or packages addressed as shown below by the following means of service:
[×]: By Electronic Service. Based on a court order or an agreement of the parties to accept service by electronic transmission, I caused the documents to be sent to the persons at the electronic notification addresses listed below.
Teresa Renaker
Nina Wasow
Lewis, Feinberg, Lee, Renaker & Jackson, P.C.
476-9th Street
Oakland, CA 94607
Ph: 510.839.6824
Fax: 510.839.7839
trenaker@lewisfeinberg.com
nwasow@lewisfeinberg.com
Attorneys for Plaintiff, Deborah Jacobs
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct to the best of my knowledge.
EXECUTED on December 22, 2011 at San Francisco, California.
___________________________
Monique Jacquis