STIPULATION AND [PROPOSED] ORDER FOR ADDITIONAL EXTENSION OF TIME FOR DEFENDANT TO ANSWER OR OTHERWISE RESPOND TO THE COMPLAINT (THIRD REQUEST)

WILLIAM G. COBB, Magistrate Judge.

IT IS HEREBY STIPULATED by and between the parties hereto through their respective attorneys that Defendant LIFE INSURANCE COMPANY OF NORTH AMERICA (also improperly named herein as Cigna Group Insurance, Inc. and Connecticut General Life) may have an additional week in which to answer or otherwise respond to plaintiff's complaint.

This is the parties' third requested extension. The first extension was three weeks. The second request was one week. This third request is for an additional week which would require Defendant to respond on or before August 10, `.

Good cause exists for this request. The parties have agreed that Plaintiff will amend the complaint to reflect a claim for relief under ERISA and remedies that are consistent with ERISA. The parties anticipate that Plaintiff will file the amended complaint within the next 7 (seven) days. By granting this additional extension, the Court will avoid the need for the parties and the Court to expend resources on a motion to dismiss for failure to state a claim on which relief can be granted.

This extension will not affect any existing deadline already scheduled by the Court.

This document is being electronically filed through the Court's ECF System. In this regard, counsel for Defendant hereby attests that (1) the content of this document is acceptable to all persons required to sign the document, (2) Plaintiff has concurred with the filing of this document; and (3) a record supporting this concurrence is available for inspection or production if so ordered.

IT IS SO ORDERED.