Travelers Property Casualty Company of America v. Old Republic Insurance Company, et al

Filing 31

Stipulation and Order to extend time to file a responsive pleading, signed by Magistrate Judge Barbara A. McAuliffe on 06/04/2013. (Defendant National Union Answer or Response due by 6/13/2013) (Figueroa, O)

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1 2 3 4 5 6 7 8 ANDREW D. HEROLD, ESQ., Bar No. 178640 aherold@heroldsagerlaw.com KENDALL DULICH, ESQ., Bar No 178307 kdulich@heroldsagerlaw.com HEROLD & SAGER 550 Second Street, Suite 200 Encinitas, CA 92024 (760) 487-1047 / (760) 487-1064 FAX Attorneys for Defendants CHARTIS SPECIALTY INSURANCE COMPANY fka AMERICAN INTERNATIONAL SPECIALTY LINES INSURANCE COMPANY and NATIONAL UNION FIRE INSURANCE COMPANY 9 10 UNITED STATES DISTRICT COURT 11 EASTERN DISTRICT OF CALIFORNIA 12 13 TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA, a Connecticut corporation, 14 15 16 17 Case No. 1:13-cv-00576-LJO-BAM STIPULATION AND ORDER TO EXTEND TIME TO FILE A RESPONSIVE PLEADING Plaintiff, v. (Doc. 27) OLD REPUBLIC INSURANCE COMPANY, a Pennsylvania corporation; et al; and DOES 1 through 10 inclusive, 18 Defendants. 19 20 This Stipulation is entered into by and between Plaintiff TRAVELERS PROPERTY 21 CASUALTY COMPANY OF AMERICA (“Travelers”) and Defendant NATIONAL UNION 22 FIRE INSURANCE COMPANY (“National Union”) by and through their respective attorneys’ of 23 record. 24 RECITALS 25 1. WHEREAS Travelers filed its complaint in the instant action on April 19, 2013; 26 2. WHEREAS Travelers served National Union on May 9, 2013 with the summons 27 and complaint in this action; 28 1 1 2 3. Union to respond to the complaint; IT IS HEREBY STIPULATED AND AGREED: 3 4 5 6 WHEREAS Travelers and National Union have agreed to an extension for National 4. Subject to the Court’s approval, National Union shall file a responsive pleading to the complaint on or before June 13, 2013. 5. This stipulation shall not constitute an appearance by National Union. National 7 Union does not waive its right to challenge the Court’s jurisdiction over this matter and/or whether 8 National Union was validly served with summons and complaint. 9 10 DATED: May 31, 2013 11 HEROLD & SAGER /s/ Andrew Herold ______________________________________ ANDREW D. HEROLD, ESQ. Attorneys for Defendants Chartis Specialty Insurance Company and National Union Fire Insurance Company 12 13 14 15 16 17 18 19 20 21 DATED: May 31, 2013 THE AGUILERA LAW GROUP, APLC /s/ Angela Martin (as authorized 5-31-13) ______________________________________ A. ERIC AGUILERA KARI M. MYRON ANGELA MARTIN Attorneys for Plaintiff TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA 22 23 24 25 26 27 28 2 ORDER 1 2 On May 31, 2013, Plaintiff and Defendant National Union stipulated to extend Defendants’ 3 time to file an answer or otherwise respond to Plaintiff’s Complaint. (Doc. 27). The Stipulation of 4 the parties is APPROVED. Defendant National Union shall have up to an including June 13, 2013 5 to answer or otherwise respond to Plaintiff’s Complaint. 6 7 IT IS SO ORDERED. 8 9 10 Dated: /s/ Barbara June 4, 2013 A. McAuliffe _ UNITED STATES MAGISTRATE JUDGE 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3

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