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

Filing 61

STIPULATION and ORDER to Extend Time to File a Responsive Pleading: Defendant Lexington Insurance Company response by 6/13/2013. signed by Magistrate Judge Barbara A. McAuliffe on 6/10/2013. (Herman, H)

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ANDREW D. HEROLD, ESQ., Bar No. 178640
[e-mail]
KENDALL DULICH, ESQ., Bar No 178307
[e-mail]
HEROLD & SAGER
550 Second Street, Suite 200
Encinitas, CA 92024
[phone] / [phone] FAX
Attorneys for Defendants
CHARTIS SPECIALTY INSURANCE COMPANY fka AMERICAN INTERNATIONAL
SPECIALTY LINES INSURANCE COMPANY and NATIONAL UNION FIRE INSURANCE
COMPANY

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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TRAVELERS PROPERTY CASUALTY
COMPANY OF AMERICA, a Connecticut
corporation,

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STIPULATION AND ORDER TO EXTEND
TIME TO FILE A RESPONSIVE
PLEADING

Plaintiff,

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Case No. 1:13-cv-00576-LJO-BAM

v.
OLD REPUBLIC INSURANCE
COMPANY, a Pennsylvania corporation; et
al; and DOES 1 through 10 inclusive,

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Defendants.

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This Stipulation is entered into by and between Plaintiff TRAVELERS PROPERTY

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CASUALTY COMPANY OF AMERICA (“Travelers”) and Defendant LEXINGTON

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INSURANCE COMPANY (“Lexington”) by and through their respective attorneys’ of record.

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RECITALS

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1.

WHEREAS Travelers filed its complaint in the instant action on April 19, 2013;

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2.

WHEREAS Travelers served Lexington on May 2, 2013 with the summons and

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complaint in this action;

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STIPULATION AND ORDER TO EXTEND TIME TO FILE A RESPONSIVE PLEADING

1:13-cv-00576-LJO-BAM

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3.

WHEREAS Travelers and Lexington have agreed to an extension for Lexington to

respond to the complaint;
IT IS HEREBY STIPULATED AND AGREED:

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4.

Subject to the Court’s approval, Lexington shall file a responsive pleading to the

complaint on or before June 13, 2013.
5.

This stipulation shall not constitute an appearance by Lexington. Lexington does

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not waive its right to challenge the Court’s jurisdiction over this matter and/or whether Lexington

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was validly served with the summons and complaint.

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DATED: June 6, 2013

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HEROLD & SAGER
/s/ Andrew Herold
______________________________________
ANDREW D. HEROLD, ESQ.
Attorneys for Defendants
CHARTIS SPECIALTY INSURANCE COMPANY,
NATIONAL
UNION
FIRE
INSURANCE
COMPANY OF PITTSBURGH, PA, and
LEXINGTON INSURANCE COMPANY

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DATED: June 6, 2013

THE AGUILERA LAW GROUP, APLC
/s/ Angela Martin (as authorized 6-6-13)
______________________________________
A. ERIC AGUILERA
KARI M. MYRON
ANGELA MARTIN
Attorneys for Plaintiff
TRAVELERS PROPERTY
CASUALTY COMPANY OF AMERICA

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STIPULATION AND ORDER TO EXTEND TIME TO FILE A RESPONSIVE PLEADING

1:13-cv-00576-LJO-BAM

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ORDER

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Based on the above stipulation of the parties, it is hereby ORDERED that Lexington

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Insurance Company shall file a responsive pleading to Plaintiff’s Complaint on or before June 13,

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2013.

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IT IS SO ORDERED.
Dated:

/s/ Barbara

June 10, 2013

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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STIPULATION AND ORDER TO EXTEND TIME TO FILE A RESPONSIVE PLEADING

1:13-cv-00576-LJO-BAM