STIPULATION TO EXTEND RESPONSIVE PLEADING DEADLINE AND TO CONTINUE CASE MANAGEMENT

CONFERENCE; [PROPOSED] ORDER

541155.1

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THOMAS M. HERLIHY (SBN 83615)

JOHN T. BURNITE (SBN 162223)

WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP

525 Market Street, 17

th

Floor

San Francisco, CA 94105-2725

Tel.: (415) 433-0990

Fax: (415) 434-1370

Email: herlihy@wilsonelser.com

john.burnite@wilsonelser.com

Attorneys for Defendants

UNUM GROUP (formerly known as

UNUMPROVIDENT CORPORATION) and

THE PAUL REVERE LIFE INSURANCE COMPANY

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

SEAN S. MAY, M.D.

Plaintiff,

vs.

UNUMPROVIDENT CORPORATION, THE

PAUL REVERE LIFE INSURANCE

COMPANY and UNUM GROUP, inclusive,

Defendants.

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Case No.: C09-01537 VRW (ADR)

STIPULATION TO EXTEND

RESPONSIVE PLEADING DEADLINE

AND TO CONTINUE CASE

MANAGEMENT CONFERENCE;

[PROPOSED] ORDER

Case 3:09-cv-01537-JSW Document 18 Filed 05/12/10 Page 1 of 3
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STIPULATION TO EXTEND RESPONSIVE PLEADING DEADLINE AND TO CONTINUE CASE MANAGEMENT

CONFERENCE; [PROPOSED] ORDER

Case No.: C09-01537VRW (ADR0

541155.1

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The parties, plaintiff Sean S. May, M.D. and defendants Unum Group (formerly known

as UnumProvident Corporation), and The Paul Revere Life Insurance Company are in the

process of discussing settlement, which may include setting an early mediation. Accordingly,

the parties, through their respective attorneys, respectfully request that the court approve this

stipulation and extend defendants’ responsive pleading deadline and the initial case management

conference.

Pursuant to Northern District Local Rule 6-1(a), the parties, hereby stipulate that

defendants shall have an extension to respond to the complaint from May 10, 2010 to June 14,

2010.

The parties further stipulate to continue the Case Management Conference presently

scheduled for June 24, 2010 be continued to July 29, 2010.

Good cause exists for the parties’ stipulation and proposed order insofar the continued

dates will promote the public policy of encouraging parties to explore early resolution of

litigation.

IT IS SO STIPULATED.

KNOX RICKSEN, LLP

Dated: May 10, 2010 By__________/s/_________________

Thomas E. Fraysse

Attorney for Plaintiff

SEAN S. MAY, M.D.

WILSON, ELSER, MOSKOWITZ, EDELMAN &

DICKER LLP

Dated: May 10, 2010 By__________/s/____________________

Thomas M. Herlihy

John T. Burnite

Attorney for Defendants

UNUM GROUP (formerly known as

UNUMPROVIDENT CORPORATION) and THE

PAUL REVERE LIFE INSURANCE COMPANY

August 5, 2010. 

Case 3:09-cv-01537-JSW Document 18 Filed 05/12/10 Page 2 of 3
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STIPULATION TO EXTEND RESPONSIVE PLEADING DEADLINE AND TO CONTINUE CASE MANAGEMENT

CONFERENCE; [PROPOSED] ORDER

Case No.: C09-01537VRW (ADR0

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ORDER

IT IS SO ORDERED that defendants shall have an extension to respond to the complaint

from May 10 to June 14, 2010. It is further ordered that the Case Management Conference is

continued from June 24, 2010 to July 29, 2010.

Date: May ___, 2010 ___________________________________

VAUGHN R. WALKER

United States District Chief Judge

August 5, 2010 at 3:30 PM. 12

U

NITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

Judge Vaughn R Walker

Case 3:09-cv-01537-JSW Document 18 Filed 05/12/10 Page 3 of 3