Continental Casualty Company, et al v. Global Allies, LLC

Filing 20

STIPULATION and ORDER signed by Judge Morrison C. England, Jr on 6/26/12 EXTENDING Global Allies' response to Plaintiffs' Complaint to 7/20/12. (Meuleman, A)

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1 2 3 4 5 6 7 John S. Rossiter, Bar No. 151113 JRossiter@perkinscoie.com Joren Bass, Bar No. 208143 JBass@perkinscoie.com Jacqueline Young, Bar No. 280374 JYoung@perkinscoie.com PERKINS COIE LLP Four Embarcadero Center, Suite 2400 San Francisco, CA 94111-4131 Telephone: 415-344-7000 Facsimile: 415-344-7050 Attorneys for Defendant Global Allies, LLC 8 9 UNITED STATES DISTRICT COURT 10 EASTERN DISTRICT OF CALIFORNIA 11 12 13 CONTINENTAL CASUALTY COMPANY and VALLEY FORGE INSURANCE COMPANY, Plaintiffs, 14 15 16 17 Case No. 2:11-cv-03237-MCE-KJN JOINT STIPULATION AND ORDER TO EXTEND TIME FOR GLOBAL ALLIES TO FILE RESPONSIVE PLEADING v. GLOBAL ALLIES, LLC, Defendant. 18 19 20 21 22 23 24 25 26 27 28 STIPULATION AND ORDER TO EXTEND TIME TO FILE RESPONSIVE PLEADINGS NO. 2:11-CV-03237-MCE-KJN 1 I. 2 3 STIPULATION WHEREAS, on March 25, 2010, a lawsuit was filed against Defendant Global 4 Allies, LLC (“Global Allies”), in the United States District Court for the Northern District 5 of Illinois entitled Global Total Office, Ltd. et al. v. Global Allies, LLC, No. 1:10-cv- 6 01896 (hereinafter, the “GTO action”); 7 WHEREAS, on December 6, 2011, Plaintiffs Continental Casualty Company and 8 Valley Forge Insurance Company (collectively, “Plaintiffs”) filed a complaint for 9 declaratory relief pursuant to 28 U.S.C. §§ 2201 and 2202 in this Court seeking a 10 declaration that they have no duty to defend or indemnify Global Allies under Plaintiffs’ 11 insurance policies with regard to the underlying GTO action; 12 WHEREAS, the parties to the GTO action participated in a mediation on June 20, 13 2012 before the Honorable Arlander Keys, Magistrate Judge of the United States District 14 Court for the Northern District of Illinois; 15 WHEREAS, the parties to the GTO action appear to be close to a settlement in 16 principle and are scheduled to attend a Magistrate Status Hearing on June 27, 2012 before 17 Magistrate Keys to discuss the terms of the potential resolution to the GTO action; 18 19 20 WHEREAS, Plaintiff and Global Allies agree that a settlement in the GTO action may resolve or narrow the issues in this coverage action; WHEREAS, Plaintiffs and Global Allies entered into a stipulation to extend the 21 time to respond to Plaintiffs’ Complaint in this action on January 4, 2012, extending the 22 time to respond by twenty-eight (28) days; 23 WHEREAS, on February 6, 2012, Plaintiffs and Global Allies entered into a 24 stipulated eight week stay of this coverage action, which was thereafter ordered by this 25 Court on February 16, 2012; 26 WHEREAS, on April 11, 2012 Plaintiffs and Global Allies entered into a second 27 stipulated eight week stay of the coverage action, which was thereafter ordered by this 28 Court on April 15, 2012, and which terminated on June 15, 2012; -1STIPULATION AND ORDER TO EXTEND TIME TO FILE RESPONSIVE PLEADINGS NO. 2:11-CV-03237-MCE-KJN 1 WHERAS, in light of the status of the GTO action and the settlement in principle, 2 Plaintiffs and Global Allies have agreed to extend Global Allies’ time to file responsive 3 pleadings for twenty-nine (29) calendar days; 4 Now, therefore, it is hereby stipulated by Plaintiffs Continental Casualty Company 5 and Valley Forge Insurance Company and Defendant Global Allies, LLC, by and through 6 their respective attorneys, as follows: 7 1. 8 9 10 Global Allies’ response to Plaintiffs’ complaint will be filed on or before July 20, 2012. 2. By entering into this Stipulation, neither Plaintiffs nor Global Allies waive any defenses, rights, or privileges. 11 12 IT IS SO STIPULATED. 13 14 Dated: June 21, 2012 COLLIAU CARLUCCIO KEENER MORROW PETERSON & PARSONS 15 By: /s/ Robert C. Christensen Robert C. Christensen Marsha L. Morrow 16 17 Attorneys for Plaintiffs 18 19 20 Dated: June 21, 2012 PERKINS COIE LLP 21 By: /s/ John S. Rossiter, Jr. John S. Rossiter, Jr. 22 Attorney for Defendant Global Allies, LLC. 23 24 73730-0001/LEGAL23983137 25 26 27 28 -2STIPULATION AND ORDER TO EXTEND TIME TO FILE RESPONSIVE PLEADINGS NO. 2:11-CV-03237-MCE-KJN 1 II. 2 3 ORDER Pursuant to the stipulation of the parties, the time for Global Allies to respond to Plaintiffs’ Complaint is extended to July 20, 2012. 4 5 IT IS SO ORDERED. 6 7 Dated: June 26, 2012 8 __________________________________ MORRISON C. ENGLAND, JR UNITED STATES DISTRICT JUDGE 9 10 11 DEAC_Signature-END: 12 13 14 15 c4d6b0d3 16 17 18 19 20 21 22 23 24 25 26 27 28 -3STIPULATION AND ORDER TO EXTEND TIME TO FILE RESPONSIVE PLEADINGS NO. 2:11-CV-03237-MCE-KJN

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