Premier Pools Management Corp. v. Colony Insurance Co.

Filing 39

STIPULATION AND ORDER signed by District Judge John A. Mendez on 8/3/2017 PERMITTING Premier Pools Management Corp. to file a Second Amended Complaint; DEEMING said complaint filed and served effective on the date the Court approved this stipulation. (Michel, G.)

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WINTHROP LAW GROUP
Reid A. Winthrop, State Bar No. 223527
120 Newport Center Dr.
Newport Beach, California 92660
Phone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff
PREMIER POOLS MANAGEMENT CORP.
HINSHAW & CULBERTSON LLP
Robert J. Romero (SBN 136539)
One California Street, 18th Floor
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
HINSHAW & CULBERTSON LLP
Ray Tamaddon (SBN 144494)
11601 Wilshire Boulevard, Suite 800
Los Angeles, California 90025
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]
Attorneys for Defendant
COLONY INSURANCE COMPANY

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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PREMIER POOLS MANAGEMENT CORP.,
a Nevada corporation,
Plaintiff,

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vs.

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COLONY INSURANCE COMPANY, a
Virginia corporation,
Defendant.

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Case No. 13-cv-02038-JAM-EFB
Hon. John A. Mendez
STIPULATION AND ORDER RE: FILING
OF SECOND AMENDED COMPLAINT
Complaint Filed; October 1, 2013
Trial Date: July 9, 2018

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– CASE NO. 13-cv-02038-JAM-EFB

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Plaintiff Premier Pools Management Corp. (“Premier Pools”), on the one hand, and

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Defendant Colony Insurance Company (“Colony”), on the other hand, by and through their

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respective counsel of record, hereby stipulate and agree as follows:

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WHEREAS, Premier Pools desires to file the [Proposed] Second Amended Complaint

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attached hereto as Exhibit A. Exhibit B hereto is a redlined version of the [Proposed] Second

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Amended Complaint, and shows the differences between the first amended complaint and the

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[Proposed] Second Amended Complaint. Premier Pools has asked Colony to stipulate to the filing

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of the [Proposed] Second Amended Complaint.

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WHEREAS, Colony disputes the allegations in the [Proposed] Second Amended
Complaint, but agrees to its filing;

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WHEREAS, Colony’s stipulation to the filing of the [Proposed] Second Amended
Complaint is not a concession as to the merits of any claims or allegations therein.

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NOW, THEREFORE, IT IS HEREBY STIPULATED, by and among Premier Pools and
Colony, through their respective counsel of record, as follows:

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attached hereto as Exhibit A;

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Premier Pools shall be permitted to file the [Proposed] Second Amended Complaint

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The [Proposed] Second Amended Complaint attached as Exhibit A hereto shall be

deemed filed and personally served on the date the Court approves this stipulation.

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IT IS SO STIPULATED.

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Dated: August 3, 2017

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Respectfully submitted,

Respectfully submitted,

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/s/

/s/

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HINSHAW & CULBERTSON LLP
Robert J. Romero
One California Street, 18th Floor
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]

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Ray Tamaddon

Reid A. Winthrop

WINTHROP LAW GROUP
Reid A. Winthrop
120 Newport Center Dr.
Newport Beach, California 92660
Phone: [phone]
Fax: [phone]
[e-mail]

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1

– CASE NO. 11-cv-01554-MCE-JFM

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HINSHAW & CULBERTSON LLP
Ray Tamaddon
11601 Wilshire Boulevard, Suite 800
Los Angeles, California 90025
Telephone:
[phone]
Facsimile:
[phone]
[e-mail]

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ORDER
IT IS SO ORDERED.

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Dated: 8/3/2017

/s/ John A. Mendez
Judge Of The United States District Court for
the Eastern District of California

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– CASE NO. 11-cv-01554-MCE-JFM