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ROBERT M. YOUNG, Jr. (#063297) 

Email: robert.young@wilsonelser.com

SHERIDA A. STROBLE (#212707) 

Email: sherry.stroble@wilsonelser.com

WILSON, ELSER, MOSKOWITZ, 

EDELMAN & DICKER LLP

555 So. Flower Street, Suite 2900 

Los Angeles, California 90071 

Telephone:(213) 443-5100 

Facsimile: (213) 443-5101 

Attorneys for Defendant 

THE PRUDENTIAL INSURANCE COMPANY 

OF AMERICA, 

THE UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA 

ALFRED J. ANTONINI, 

Plaintiff, 

v. 

THE PRUDENTIAL INSURANCE 

COMPANY OF AMERICA; THE 

PRUDENTIAL WELFARE BENEFITS 

PLAN; THE PRUDENTIAL 

RETIREMENT PLAN, 

Defendants. 

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Case No.: CIV. 04-0505 WBS KJM -PS

The Hon. William B. Shubb 

AMENDED STIPULATION AND 

[PROPOSED] ORDER BETWEEN 

PARTIES FOR CONTINUANCE OF 

SET DATES, INCLUDING TRIAL 

IT IS HEREBY STIPULATED TO by and between plaintiff, ALFRED J. 

ANTONINI, representing himself, and defendant, PRUDENTIAL INSURANCE 

COMPANY OF AMERICA, by and through its attorney of record, Sherida A. 

Stroble of Wilson, Elser, Moskowitz, Edelman & Dicker LLP, that all dates 

previously set by this court, including trial dates and motion cut-off dates, be 

continued for a period of 90 days or more, to permit Plaintiff to retain counsel and 

to permit the parties to engage in meaningful settlement negotiations. 

This matter is a claim for benefits under the 1974 ERISA statute. The parties 

request a further continuance to allow Plaintiff time to retain counsel to represent 

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Case 2:04-cv-00505-WBS -KJM Document 29 Filed 05/24/06 Page 1 of 4
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him, as well as for the parties to attempt resolution, once Plaintiff retains counsel, 

before additional time and expense are expended in trial briefs or further litigation. 

The parties have previously requested two continuances. However, due to the 

breadth of the record (the Plaintiff’s employment ended effective January 4, 1980), 

the fact that Plaintiff has been proceeding without an attorney, and the fact that 

Plainitff is currently interviewing prospective counsel to represent him, the Parties 

request an additional 90 days. 

This request is made in good faith. 

Specifically, the parties propose the following dates, or any dates thereafter that 

accommodate the Court’s calendar, which reflect a continuance period of 90 days 

or more, to accommodate plaintiff’s efforts to obtain counsel and the parties’ 

efforts at informal resolution: 

October 2, 2006 Motion cut-off date 

November 6, 2006 Pre-trial conference 

December 5, 2006 Trial 

Dated: May 23, 2006 WILSON, ELSER, MOSKOWITZ, 

EDELMAN & DICKER LLP 

By: /s/ 

Robert M. Young, Jr. 

Sherida A. Stroble 

Attorneys for Defendant 

THE PRUDENTIAL INSURANCE 

COMPANY OF AMERICA 

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Dated: May 23, 2006 ALFRED J. ANONTINI 

By: /s/ 

Alfred J. Antonini 

Plaintiff 

ORDER

 The motion cut-off date is extended to October 2, 2006. The trial in this matter 

is continued to December 5, 2006 at 9:00 a.m. The pretrial conference is continued 

to November 6, 2006 at 10:00 am. 

IT IS SO ORDERED. 

Dated: May 23, 2006 

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PROOF OF SERVICE 

STATE OF CALIFORNIA, COUNTY OF LOS ANGELES

I am employed in the County of Los Angeles, State of California, by 

WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP and am over the 

age of 18 and not a party to the within action. My business address is 555 South 

Flower Street, 29th Floor, Los Angeles, California 90071. 

On May 22, 2006, I served the foregoing document described as 

AMENDED STIPULATION AND [PROPOSED] ORDER BETWEEN 

PARTIES FOR CONTINUANCE OF SET DATES, INCLUDING TRIAL on 

all interested parties, through their respective attorneys of record in this action, by 

placing a true copy thereof enclosed in a sealed envelope addressed as follows: 

ALFRED J. ANTONINI 

P.O. Box 0090 

Hayward, California 94543 

-or22572 Main Street 

Hayward, California 94541 

Plaintiff, In Pro Per 

Telephone: (510) 881-4981 

Facsimile: (510) 881-1647 

aainvestments@sbcglobal.net

[X] (BY MAIL) I caused such envelope(s) fully prepaid to be placed in 

the United States Mail at Los Angeles, California. I am “readily familiar” with the 

firm’s practice of collection and processing correspondence or mailing. Under that 

practice it would be deposited with the U.S. postal service on that same day with 

postage thereon fully prepaid at Los Angeles, California in the ordinary course of 

business. I am aware that on motion of the party served, service is presumed 

invalid if postal cancellation date or postage meter date is more than one day after 

date of deposit for mailing in affidavit. 

[] (BY FACSIMILE) I caused said document(s) to be telephonically 

transmitted to each addressee’s telecopier (Fax) number as noted. 

[X] (Federal) I declare that I am employed in the office of a member of 

the bar of this court at whose direction the service was made. 

Executed on May 22, 2006, at Los Angeles, California. 

 ________________ ___________ 

 ERIKA FACUNDO 

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