Free Stipulation - District Court of California - California

Case 3:07-cv-05730-WHA

Document 5

Filed 12/18/2007

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LAW OFFICES OF P. RANDALL NOAH P. RANDALL NOAH ­ State Bar No. 130892 8 Camino Encinas, Suite 200 Orinda, California 94563 Telephone (925) 253-5440 Facsimile: (925) 253-5442 Attorneys for Plaintiff RITA RICHCREEK RIMAC & MARTIN, P.C. JOSEPH M. RIMAC - State Bar No. 72381 ANNA M. MARTIN - State Bar No. 154279 [email protected] 1051 Divisadero Street San Francisco, California 94115 Telephone (415) 561-8440 Facsimile (415) 561-8430 Attorneys for Defendants UNUM LIFE INSURANCE COMPANY OF AMERICA

UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA

E-FILING
RITA RICHCREEK, ) ) CASE NO. C07­05730 WHA Plaintiff, ) ) STIPULATION TO ENLARGE TIME TO vs. ) RESPOND TO COMPLAINT ) UNUM LIFE INSURANCE COMPANY OF ) AMERICA, ) ) Defendant. ) ______________________________________ ) IT IS HEREBY STIPULATED by and between the parties hereto, through their respective attorneys of record herein, that the time for defendant to respond to plaintiff's complaint be enlarged by two weeks. Defendant's response is currently due on December 21, 2007 and it is stipulated that defendant may have up to and including January 4, 2008 to respond. Good cause exists therefor in that defense counsel has just received a copy of the administrative record in this matter and requires time to review the materials and formulate a -1STIPULATION FOR ENLARGEM ENT OF TIM E TO RESPOND TO COM PLAINT

CASE NO. C 07-05730 WHA

Case 3:07-cv-05730-WHA

Document 5

Filed 12/18/2007

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response to plaintiff's complaint, given the time constraints presented by the holiday period in the last week of December 2007. Pursuant to local rules, this document is being electronically filed through the Court's ECF System. In this regard, counsel for defendant hereby attests that (1) the content of this document is acceptable to all persons required to sign the document; (2) plaintiff's counsel has concurred with the filing of this document; and (3) a record supporting this concurrence is available for inspection or production if so ordered. SO STIPULATED. RIMAC & MARTIN, P.C.

DATED: December 18, 2007

By:

/S/ ANNA M. MARTIN ANNA M. MARTIN Attorneys for Defendant UNUM LIFE INSURANCE COMPANY OF AMERICA LAW OFFICES OF P. RANDALL NOAH

15 16 DATED: December 18, 2007 17 18 19 20 21 22 23 24 25 26 27 28 -2STIPULATION FOR ENLARGEM ENT OF TIM E TO RESPOND TO COM PLAINT

By:

/S/ P. RANDALL NOAH P. RANDALL NOAH Attorneys for Plaintiff RITA RICHCREEK

CASE NO. C 07-05730 WHA