STIPULATION AND ORDER TO EXTEND TIME TO AMEND COMPLAINT AND RESPOND TO COMPLAINT (First Request

RICHARD F. BOULWARE, II, District Judge.

Pursuant to LR IA 6-1, 6-2, and LR 7-1, Defendant, Sun Life Assurance Company of Canada ("Sun Life"), and Ana Teresa Phillips ("Plaintiff") by and through their undersigned counsel of record, HEREBY STIPULATE AND AGREE AS FOLLOWS:

1. Plaintiff filed her Complaint in the instant action on August 18, 2016.

2. Sun Life filed its timely Notice of Removal with this Court on October 4, 2016. [ECF No. 1.]

3. Sun Life and Plaintiff conferred, through counsel, on or about October 6, 2016 regarding governing law of the claims asserted in the Complaint.

4. Sun Life and Plaintiff have agreed that this Court has federal question jurisdiction over the claims in the Complaint under the Employee Retirement Income Security Act of 1974, 29 U.S.C. § 1001 et seq. (hereinafter "ERISA");

5. Sun Life and Plaintiff have agreed to an extension of time for Plaintiff to amend her Complaint under ERISA. Therefore, Plaintiff's deadline to amend the Complaint is now October 17, 2016.

6. Sun Life and Plaintiff have agreed that Sun Life shall have twenty-eight (28) days from the Plaintiff's deadline to amend the Complaint, in which to respond. Therefore, Sun Life's deadline to respond to the Complaint is now November 14, 2016.

7. This is the parties' first request to extend the deadlines.

8. This request is made in good faith, and not for purposes of delay.

IT IS SO STIPULATED:

IT IS SO ORDERED.