Nautilus Insurance Company v. Access Medical, LLC et al

Filing 26

Second STIPULATION and ORDER to Extend Time for Defendants Access Medical, LLC and Robert Clark Wood, II, to Respond to Initial Complaint: time to respond to Plaintiff Nautilus's Complaint is extended until January 23, 2015. signed by Magistrate Judge Barbara A. McAuliffe on 1/13/2015. (Herman, H)

1 LINDA WENDELL HSU (SBN 162971)
[e-mail]
2 QUYEN THI LE (SBN 271692)
[e-mail]
3 SELMAN BREITMAN LLP
33 New Montgomery, Sixth Floor
4 San Francisco, CA 94105-4537
Telephone: [phone]
5 Facsimile: 415.979.2099
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Attorneys for Plaintiff NAUTILUS INSURANCE COMPANY
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA
NAUTILUS INSURANCE COMPANY,

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ATTORNEYS AT LAW

Selman Breitman

LLP

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Plaintiff,
v.

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Case No. 1:14-cv-01591-GEB-BAM
SECOND STIPULATION AND ORDER TO
EXTEND TIME FOR DEFENDANTS ACCESS
MEDICAL, LLC AND ROBERT CLARK WOOD,
II, TO RESPOND TO INITIAL COMPLAINT

ACCESS MEDICAL, LLC; ROBERT
Judge:
Garland E. Burrell, Jr.
14 CLARK WOOD, II; FLOURNOY
MANAGEMENT, LLC; TED SWITZER; and
Complaint Filed:
October 10, 2014
15 DOES 1-10, inclusive,
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Defendants.

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Complaint Served:
Original Response Date:
Current Response Date:
New Response Date:

December 4, 2014
December 26, 2014
January 9, 2015
January 23, 2015

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Pursuant to Local Rule 144, Plaintiff NAUTILUS INSURANCE COMPANY

21 ("Nautilus") and DEFENDANTS ACCESS MEDICAL, LLC ("Access Medical") and ROBERT
22 CLARK WOOD, II ("Wood"), by and through their respective counsel of record, hereby
23 stipulate as follows:
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WHEREAS, Plaintiff Nautilus filed its Complaint for Declaratory Relief on October 10,

25 2014;
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WHEREAS, Plaintiff alleges that it served the Summons and Complaint on Defendants

27 Access Medical and Wood by substituted service on December 4, 2014, making their original
28 deadline to respond to the Complaint as December 26, 2014;
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SECOND STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS ACCESS MEDICAL, LLC
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305640.2 3891.35805

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AND ROBERT CLARK WOOD, II, TO RESPOND TO INITIAL COMPLAINT
1:14-cv-01591-GEB-BAM

1

WHEREAS, the parties previously agreed that Access Medical and Wood may have an

2 extension of time until January 9, 2015, to respond to Plaintiff's Complaint;
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WHEREAS, the parties require additional time to evaluate the claims, and therefore have

4 agreed for a second extension of time, until and including January 23, 2015, for Access Medical
5 and Wood to respond to Plaintiff's Complaint;
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IT IS SO STIPULATED between Plaintiff Nautilus, on the one hand, and Defendants

7 Access Medical and Wood, on the other, by and through their undersigned attorneys, that the
8 time for Access Medical and Wood to respond to Plaintiff Nautilus's Complaint is extended until
9 and including January 23, 2015.
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IT IS FURTHER STIPULATED between the parties that by entering in to this

12 of Civil Procedure, Rule 12, including venue, jurisdiction, insufficient process or insufficient
ATTORNEYS AT LAW

Selman Breitman

LLP

11 stipulation, Access Medical and Wood have not waived any defenses pursuant to Federal Rules

13 service of process.
14 DATED: January 9, 2015

KRAVITZ, SCHNITZER & JOHNSON,
CHTD.

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By: _____/s/ Jordan P. Schnitzer
JORDAN P. SCHNITZER
Attorneys for Defendants ACCESS MEDICAL,
LLC and ROBERT CLARK WOOD, II

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DATED: January 9, 2015

SELMAN BREITMAN LLP

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By: _____/s/ Quyen Thi Le
LINDA WENDELL HSU
QUYEN THI LE
Attorneys for Plaintiff NAUTILUS
INSURANCE COMPANY

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305640.2 3891.35805

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2
SECOND STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS ACCESS MEDICAL, LLC
AND ROBERT CLARK WOOD, II, TO RESPOND TO INITIAL COMPLAINT
1:14-cv-01591-GEB-BAM

ORDER

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The Court has reviewed the parties’ agreement and adopts the stipulation. The time for

3 Access Medical and Wood to respond to Plaintiff Nautilus's Complaint is extended until and
4 including January 23, 2015.
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IT IS SO ORDERED.
Dated:

/s/ Barbara

January 13, 2015

A. McAuliffe

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UNITED STATES MAGISTRATE JUDGE

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ATTORNEYS AT LAW

Selman Breitman

LLP

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305640.2 3891.35805

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SECOND STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANTS ACCESS MEDICAL, LLC
AND ROBERT CLARK WOOD, II, TO RESPOND TO INITIAL COMPLAINT
1:14-cv-01591-GEB-BAM