-1- CASE NO. C 09-01163 MMC 

 STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING DATE

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ROBOOSTOFF & KALKIN 

SCOTT KALKIN Bar No. 120791 

robokalk@earthlink.net

369 Pine Street, Suite 820 

San Francisco, California 94104 

Telephone: (415) 732-0282 

Facsimile: (415) 732-0287 

JULIAN M. BAUM & ASSOCIATES 

JULIAN M. BAUM Bar No. 130892 

JMB@JMBLawGroup.com 

9 Tenaya Lane 

Novato, California 94947 

Telephone: (415) 963-4424 

Facsimile: (888) 452-3849 

Attorneys for Plaintiff PENNY BENDER 

SEDGWICK, DETERT, MORAN & ARNOLD LLP 

BRUCE D. CELEBREZZE Bar No. 102181 

DENNIS G. ROLSTAD Bar No. 150006 

ERIN A. CORNELL Bar No. 227135 

One Market Plaza 

Steuart Tower, 8th Floor 

San Francisco, California 94105 

Telephone: (415) 781-7900 

Facsimile: (415) 781-2635 

dennis.rolstad@sdma.com 

Attorneys for Defendants 

HARTFORD LIFE INSURANCE COMPANY;

BERTELSMANN, INC. EMPLOYEE PROTECTION

PLAN NUMBER 503 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

PENNY BENDER, 

Plaintiff, 

v.

HARTFORD LIFE INSURANCE 

COMPANY, As Administrator and 

Fiduciary of the Bertelsmann, Inc., 

Employee Protection Plan Number 503; 

THE BERTELSMANN, INC. 

EMPLOYEE PROTECTION PLAN 

NUMBER 503, 

Defendants.

 CASE NO. C 09-01163 MMC 

STIPULATION AND [PROPOSED] 

ORDER CONTINUING HEARING DATE 

ON PARTIES’ CROSS-MOTIONS FOR 

JUDGMENT TO JULY 30, 2010 

JUDGE: Honorable Maxine M. Chesney 

Case 3:09-cv-01163-MMC Document 55 Filed 06/28/10 Page 1 of 3
 -2- CASE NO. C 09-01163 MMC 

 STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING DATE

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IT IS HEREBY STIPULATED AND AGREED by and between plaintiff Penny Bender 

(“plaintiff”) and defendants Hartford Life Insurance Company and The Bertelsmann, Inc., 

Employee Protection Plan Number 503 (collectively “defendants”), by and through their 

attorneys of record herein, that the hearing on the parties’ cross motions for judgment be 

continued from July 16, 2010 to July 30, 2010: 

1. On April 27, 2010, the Court granted plaintiff’s motion to re-open discovery to take 

the deposition of Bruce Luddy, a Hartford employee, and set a briefing schedule for the parties 

to file supplement briefs on their cross-motions for judgment following Mr. Luddy’s deposition. 

The deposition took place on May 28, 2010. 

2. Plaintiff was ordered to file her supplemental Opposition and Reply on or before June 

11, 2010, and defendants were ordered to file their Supplemental Sur-Reply on or before June 

25, 2010. 

3. The hearing on the parties’ cross-motions for judgment was set for July 16, 2010 at 

9:00 a.m. 

4. Good cause exists to continue the hearing to July 30, 2010, as counsel for defendants 

is unavailable on July 16, 2010. 

WHEREAS, the parties hereby stipulate, agree, and respectfully request that the Court 

continue the hearing date for the cross-motions for judgment to July 30, 2010 at 9:00 a.m. The 

continuance will not affect the briefing schedule, and defendants’ Supplemental Sur-Reply will 

remain due to be filed on or before June 25, 2010. 

SO STIPULATED, AGREED, AND RESPECTFULLY REQUESTED: 

DATED: June 24, 2010 ROBOOSTOFF & KALKIN 

 JULIAN M. BAUM & ASSOCIATES 

By: s/Scott Kalkin 

s/Julian M. Baum 

Scott Kalkin 

Julian M. Baum 

Attorneys for Plaintiff 

 PENNY BENDER 

Case 3:09-cv-01163-MMC Document 55 Filed 06/28/10 Page 2 of 3
 -3- CASE NO. C 09-01163 MMC 

 STIPULATION AND [PROPOSED] ORDER TO CONTINUE HEARING DATE

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DATED: June 24, 2010 SEDGWICK, DETERT, MORAN & ARNOLD LLP 

By: s/Dennis G. Rolstad 

Dennis G. Rolstad 

Erin A. Cornell 

Attorneys for Defendants 

HARTFORD LIFE INSURANCE COMPANY; 

BERTELSMANN, INC. EMPLOYEE PROTECTION 

PLAN NUMBER 503 

I hereby attest that I have on file all holograph signatures for any signatures indicated by 

a "conformed" signature (/s/) within this e-filed document. 

 s/Dennis G. Rolstad 

 Dennis G. Rolstad 

ORDER

IT IS HEREBY ORDERED that the hearing for the parties’ cross-motions for judgment 

is continued to July 30, 2010 at 9:00 a.m. 

DATED: 

HONORABLE MAXINE M. CHESNEY 

June 28, 2010

Case 3:09-cv-01163-MMC Document 55 Filed 06/28/10 Page 3 of 3