Stipulation

Cal. Super. - 6th Dist.January 4, 2021

TROUTMAN PEPPER HAMILTON SANDERS LLP 5 PARK PLAZA SUITE 1400 IRVINE, CA 92614-2545 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 21 CV375437 Santa Clara - Civil TROUTMAN PEPPER HAMILTON SANDERS LLP Electronically Filed Chad Fuller, Bar No. 190830 by Superior Court of CA, chad.fuller@tr0utman.com County of Santa Clara, 11682 El Camino Real, Suite 400 on 4/1 2/2021 3:04 pM San Diego, CA 92130-2092 . _ Telephone: 858.509.6000 Rev'ewed By- '-- Nguyen Facsimile; 858.509.6040 Case #21CV375437 Envelope: 6222685 Jenna Uyen Nguyen, Bar No. 307929 jenna.nguyen@troutman.com 5 Park Plaza, Suite 1400 Irvine, CA 92614-2545 Telephone: 949.622.2700 Facsimile: 949.622.2739 Attorneys for Defendant ANTHEM INSURANCE COMPANIES, INC. SUPERIOR COURT OF THE STATE OF CALIFORNIA COUNTY OF SANTA CLARA STANFORD HEALTH CARE, a California nonprofit corporation, Case N0. 21CV375437 STIPULATION TO EXTEND THE TIME Plaintiff, FOR DEFENDANT TO RESPOND TO THE COMPLAINT V. ANTHEM INSURANCE COMPANIES, Current Response Date: April 19, 2021 INC., an Indiana corporation; and DOES 1 New ReSponse Date: May 19’ 2021 THROUGH 25, INCLUSIVE, Aqtion Filed: January 4, 2021 Defendant. Tnal Date: None Pursuant to California Rules of Court, Rule 3.110(6), Plaintiff Stanford Health Care, (“Plaintiff”) and Defendant Anthem Insurance Companies, Inc. (“Anthem”) (collectively, “the Parties”), hereby stipulate that Anthem’s deadline t0 respond t0 Plaintiff’s Complaint, which is currently April 19, 2021, is extended up to and including May 19, 2021; WHEREAS, Plaintiff filed the Complaint in the above-captioned action 0n January 4, 2021; WHEREAS, Plaintiff served Anthem with the Complaint on February 17, 2021; WHEREAS, the deadline for Anthem t0 respond t0 Plaintiff’s Complaint is March 19, 2021; 115072011v1 - 1 - STIPULATION TO EXTEND THE TIME FOR DEFENDANT TO RESPOND TO THE COMPLAINT TROUTMAN PEPPER HAMILTON SANDERS LLP 5 PARK PLAZA SUITE 1400 IRVINE, CA 92614-2545 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 WHEREAS, the Parties have stipulated and agreed, subject to the Court’s approval, to extend the time for Anthem t0 file and serve their response to the Complaint by thirty (30) days, thereby extending such deadline from April 19, 2021 to May 19, 2021; WHEREAS, good cause exists for the stipulated extension because the Parties are engaged in good faith discussions and research with respect to the claim at issue in this case and may likely resolve the claims without further litigation; WHEREAS, in order t0 allow the Parties t0 continue pursuing potential early resolution of these claims prior to incurring further attorneys’ fees and litigation expenses, the Parties agree t0 extend the time for Anthem to respond to Plaintiff’s Complaint up to and April 19, 2021. Dated: April 9, 2021 TROUTMAN PEPPER HAMILTON SANDERS LLP By: Chad Fuller Jenna Uyen Nguyen Attorneys for Defendant ANTHEM INSURANCE COMPANIES, INC. Dated: April 9, 2021 LAW OFFICES OF STEPHENSON, ACQUISTO & COLMAN, INC. By: Signed for and approved by: Christopher Hapak Attorney for Plaintiff STANFORD HEALTH CARE 115072011v1 - 2 - STIPULATION TO EXTEND THE TIME FOR DEFENDANT TO RESPOND TO THE COMPLAINT TROUTMAN PEPPER HAMILTON SANDERS LLP 11682 EL CAMINO REAL SUITE 400 SAN DIEGO, CA 92130-2092 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PROOF OF SERVICE STATE OF CA, COUNTY OF SAN DIEGO I am employed in the County of San Diego, State of CA. I am over the age 0f 18 and not a party to the within action; my business address is 11682 E1 Camino Real, Suite 400, San Diego, CA 92 1 30-2092. On April 12, 2021, I served the following document(s) described as: STIPULATION TO EXTEND THE TIME FOR DEFENDANT TO RESPOND TO THE COMPLAINT BY MAIL: As follows: I am readily familiar with the firm’s practice of collection and processing correspondence for mailing. Under that practice it would be deposited with U.S. postal service on that same day With postage thereon fully prepaid at San Diego, CA, in the ordinary course of business. I am aware that 0n motion of the party served, service is presumed invalid if postage cancellation date or postage meter date is more than one day after date 0f deposit for mailing in affidavit. BY OVERNIGHT MAIL: As follows: I am readily familiar with the firm’s practice of collection and processing correspondence for overnight mailing. Under that practice, it would be deposited with overnight mail 0n that same day prepaid at San Diego, CA in the ordinary course of business. BY ELECTRONIC MAIL (CRC 2.25 1): Based on a court order or an agreement of the parties to accept service by e-mail or electronic transmission, I caused the documents t0 be sent t0 the persons at the e-mail addresses, as last given or submitted 0n any document Which he 0r she has filed in the case, listed on the attached service list. Christopher Hapak Law Offices 0f Stephenson, Acquisto & Colman, Inc. 303 N. Glenoaks Blvd., Suite 700 Burbank, CA 91502 (818) 559-4477 chapak@sacfirm.com cc: Angela Demers - ademers@sacfirm.com Attorneys for Plaintiff Stanford Health Care 115161732v1 PROOF OF SERVICE TROUTMAN PEPPER HAMILTON SANDERS LLP 11682 EL CAMINO REAL SUITE 400 SAN DIEGO, CA 92130-2092 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I declare under penalty 0f perjury under the laws 0f the State 0f California that the above is true and correct. Executed 0n April 12, 2021, at San Diego, CA.4mm Erika K. Schmidt 115161732V1 _ 2 _ PROOF OF SERVICE