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STIPULATION AND PROPOSED ORDER 

CONTINUING THE TRIAL 

KRAFCHICK LAW FIRM 

100 W. Harrison St, S. Tower, #300 

Seattle, WA 98119 

Case No. CV-09-0452 JL

Steven P. Krafchick 

Washington State Bar No. 13542 

Pro Hac Vice 

KRAFCHICK LAW FIRM 

100 W. Harrison, South Tower, Suite 300 

Seattle, WA 98119 

(206) 374-7370 (Telephone) 

(206) 374-7377 (Facsimile) 

klf@krafchick.com 

Mr. Abraham N. Goldman 

California State Bar No. 102080 

ABRAHAM N. GOLDMAN & ASSOCIATES, LTD 

P.O. Box 120 / 12896 Rices Crossing Road 

Oregon House, CA 95962 

(530) 692-2267 (Telephone) 

(530) 692-2543 (Fax) 

agoldman@succeed.net

Attorneys for Plaintiff TAMARA KNOPP 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

TAMARA KNOPP, 

Plaintiff, 

v. 

LIFE INSURANCE COMPANY OF 

NORTH AMERICA, and NOVARTIS 

VACCINES AND DIAGNOSTIC, INC. 

INSURANCE PLAN, 

Defendants. 

Case No. CV-09-0452 CB 

STIPULATION AND [PROPOSED] 

ORDER CONTINUING THE TRIAL AND 

THE PRETRIAL CONFERENCE IN THIS 

MATTER 

HON: CHARLES BREYER 

TRIAL DATE: MARCH 29, 2010 

 PRE-TRIAL: MARCH 22, 2010 

 

Case 3:09-cv-00452-CRB Document 58 Filed 03/11/10 Page 1 of 4
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STIPULATION AND PROPOSED ORDER 

CONTINUING THE TRIAL 2. 

KRAFCHICK LAW FIRM 

100 W. Harrison St, S. Tower, #300 

Seattle, WA 98119 

Case No. CV-09-0452 JL

Plaintiff TAMARA KNOPP and Defendants LIFE INSURANCE COMPANY OF NORTH 

AMERICA and NOVARTIS VACCINES AND DIAGNOSTIC, INC. INSURANCE PLAN 

(collectively “the Parties”), through their respective counsel, hereby request and stipulate to a 

continuance of the pretrial conference and trial in this matter, currently set for March 23, 2010, 

March 29, 2010, respectively, for the following reasons: 

This matter involves a bench trial under the Employee Retirement Income Security Act of 

1974 (“ERISA”). This matter currently is set for a bench trial on March 29, 2010 with a pretrial 

conference set for March 22, 2010. 

Settlement negotiations have been on-going since February 1, 2010. Significant progress has 

been made toward settlement with concessions by all Parties, but the Parties have not been able to 

come to a complete agreement as of March 5, 2010. Negotiations continue and slightly more time 

will benefit the negotiations. 

The parties request a telephone settlement conference with the Magistrate assigned to this 

matter on a date as soon as reasonably possible that works for all parties and counsel. 

In addition, additional time is needed to complete court ordered discovery in the event this 

matter does not settle. 

Finally, the current trial date of March 29, 2010 is the start of the Passover holiday making it 

both highly inconvenient and prohibitive for both Steven Krafchick and Abraham Goldman, 

Plaintiff’s counsel. Defendants’ counsel, Sean Nalty, has no objection to moving the trial date in 

order to accommodate Plaintiff’s counsel. 

The parties suggest any of the following dates for the new trial: May 3, May 10, May 17 or 

June 7. 

Based on the forgoing, the parties hereby stipulate that the trial in this matter can be moved 

to May 3, May 10, May 17, or June 7 and respectfully request that the Court continue the trial and 

the pre-trial conference accordingly. 

Case 3:09-cv-00452-CRB Document 58 Filed 03/11/10 Page 2 of 4
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STIPULATION AND PROPOSED ORDER 

CONTINUING THE TRIAL 3. 

KRAFCHICK LAW FIRM 

100 W. Harrison St, S. Tower, #300 

Seattle, WA 98119 

Case No. CV-09-0452 JL

Dated: March 8th, 2010 

/s/ Steven P. Krafchick___

STEVEN P. KRAFCHICK 

KRAFCHICK LAW FIRM 

/s/ Abraham N. Goldman___

ABRAHAM N. GOLDMAN 

California State Bar No. 102080 

ABRAHAM N. GOLDMAN & 

ASSOCIATES, LTD 

Attorneys for Plaintiff 

TAMARA KNOPP 

 

Dated: March 8th, 2010 

/s/ Sean P. Nalty 

SEAN P. NALTY 

WILSON ELSER 

Attorneys for Defendant 

LIFE INSURANCE COMPANY OF NORTH 

AMERICA 

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STIPULATION AND PROPOSED ORDER 

CONTINUING THE TRIAL 4. 

KRAFCHICK LAW FIRM 

100 W. Harrison St, S. Tower, #300 

Seattle, WA 98119 

Case No. CV-09-0452 JL

[PROPOSED] ORDER 

 Pursuant to the Stipulation above, the Trial for the above captioned matter is hereby: 

Continued to _____________, 

The clerk shall issue a new Order setting the Pre-Trial Conference accordingly; 

IT IS SO ORDERED. 

Dated: __________________ _________________________________ 

 THE HONORABLE CHARLES R. BREYER 

May 17, 2010 at 8:30 a.m.. The pre-trial conference is continued to May 11, 2010 at 2:30 p.m. March 9, 2010

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORN

I

A

IT IS SO ORDERED

Judge Charles R. Breyer

Case 3:09-cv-00452-CRB Document 58 Filed 03/11/10 Page 4 of 4