Anselmo et al v. Maryland Casualty Company et al

Filing 23

STIPULATION and ORDER 22 for extension of time signed by Senior Judge William B. Shubb on 2/2/2015. Parties have to and including 3/16/2015 to file a Stipulation of Dismissal. (Marciel, M)

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K. Greg Peterson, Esq. (SBN: 118287)
LAW OFFICES OF K. GREG PETERSON
1716 L Street
Sacramento, California 95811
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]
Attorneys for Plaintiffs ELEANOR J. ANSELMO,
individually, and as Trustee under that certain
document entitled “The Albert A. and Eleanor J.
Anselmo 1988 Revocable Trust” Dated
February 19, 1988, and as Successor-in-Interest to
Albert A. Anselmo, Deceased; ROSALIE A. ANSELMO,
individually and as Co-Trustee under that certain
document entitled “The Edward A. Anselmo
and Rosalie A. Anselmo 1992 Revocable Trust”
Dated December 21, 1992; KAREN L. LILIENTHAL,
as Co-Trustee under that certain document entitled
“The Edward A. Anselmo and Rosalie A. Anselmo
1992 Revocable Trust” Dated December 21, 1992;
DAVE DAVELAAR, individually, and
LINDA DAVELAAR, individually
Randy M. Marmor, Esq. (SBN: 074747)
SINNOTT, PUEBLA, CAMPAGNE & CURET, APLC
Two Embarcadero Center, Suite 1410
San Francisco, California 94111
Telephone: [phone];
Facsimile: [phone]
Email:
[e-mail]
Attorneys for Defendant MARYLAND CASUALTY COMPANY

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Bruce N. Telles, Esq. (SBN: 152080)
AIWASIAN & ASSOCIATES
725 S. Figueroa Street, Suite 1050
Los Angeles, CA 90017
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]
Attorneys for Defendant CENTURY INDEMNITY COMPANY

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-1STIPULATION AND REQUEST FOR LEAVE OF COURT TO EXTEND
DATE FOR FILING STIPULATION OF DISMISSAL; [PROPOSED] ORDER

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IN THE UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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ELEANOR J. ANSELMO, et al.,

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Plaintiffs,
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vs.
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MARYLAND CASUALTY COMPANY, et al., )
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Defendants.
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AND RELATED CROSS-ACTION.
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Case No.: 2:14-CV-00162-WBS-AC
STIPULATION AND REQUEST FOR
LEAVE OF COURT TO EXTEND DATE
FOR FILING STIPULATION OF
DISMISSAL; [PROPOSED] ORDER

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The following is hereby stipulated and agreed to, by and between Plaintiffs,

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ELEANOR J. ANSELMO, individually, and as Trustee under that certain document

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entitled “The Albert A. and Eleanor J. Anselmo 1988 Revocable Trust” Dated February

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19, 1988, and as Successor-in-Interest to Albert A. Anselmo, Deceased; ROSALIE A.

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ANSELMO, individually and as Co-Trustee under that certain document entitled “The

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Edward A. Anselmo and Rosalie A. Anselmo 1992 Revocable Trust” Dated December

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21, 1992; KAREN L. LILIENTHAL, as Co-Trustee under that certain document entitled

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“The Edward A. Anselmo and Rosalie A. Anselmo 1992 Revocable Trust” Dated

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December 21, 1992; DAVE DAVELAAR , individually, and LINDA DAVELAAR,

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individually, and Defendants, MARYLAND CASUALTY COMPANY, a Maryland

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corporation; and CENTURY INDEMNITY COMPANY (as successor-in-interest to CCI

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Insurance Company, as successor-in-interest to Insurance Company of North America),

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a Pennsylvania corporation, and is entered into by and through their respective counsel.

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1.

On or about December 10, 2014, the within action was settled in its

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entirety by agreement of the parties through a mediation conducted by Robert J. Kaplan,

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Esq. of Kaplan Mediation;

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-2STIPULATION AND REQUEST FOR LEAVE OF COURT TO EXTEND
DATE FOR FILING STIPULATION OF DISMISSAL; [PROPOSED] ORDER

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2.

On or about December 12, 2014, pursuant to Federal Rules of Civil

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Procedure, Rule 16 (Local Rule 160), Plaintiffs filed their Notice of Settlement, indicating

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that a Stipulation of Dismissal would be filed on or before January 30, 2015;
3.

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The Parties have been unable to finalize and execute a Confidential

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Settlement Agreement and Release in sufficient time to permit the filing of the above-

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referenced Stipulation of Dismissal, but are confident they will finalize and execute a

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mutually acceptable agreement in the very near future; and
4.

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The Parties respectfully request that the January 30, 2015 deadline for

filing the Stipulation of Dismissal be extended to March 16, 2015.
IT IS SO STIPULATED.

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Dated: January 29, 2015

LAW OFFICES OF K. GREG PETERSON

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By: /s/ K. Greg Peterson
Greg Peterson, Esq.
Attorney for Plaintiffs ELEANOR J. ANSELMO,
individually, and as Trustee under that certain
document entitled “The Albert A. and Eleanor J.
Anselmo 1988 Revocable Trust” Dated
February 19, 1988, and as Successor-inInterest to Albert A. Anselmo, Deceased;
ROSALIE A. ANSELMO, individually and as
Co-Trustee under that certain document
entitled “The Edward A. Anselmo and Rosalie
A. Anselmo 1992 Revocable Trust” Dated
December 21, 1992; KAREN L. LILIENTHAL,
as Co-Trustee under that certain document
entitled “The Edward A. Anselmo and Rosalie
A. Anselmo 1992 Revocable Trust” Dated
December 21, 1992; DAVE DAVELAAR ,
individually, and LINDA DAVELAAR,
individually

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-3STIPULATION AND REQUEST FOR LEAVE OF COURT TO EXTEND
DATE FOR FILING STIPULATION OF DISMISSAL; [PROPOSED] ORDER

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Dated: January 29, 2015

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SINNOTT, PUEBLA, CAMPAGNE &
CURET, APLC

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By: /s/ Randy M. Marmor (as authorized 1/29/15)___
Randy M. Marmor, Esq.
Attorneys for Defendant MARYLAND
CASUALTY COMPANY

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Dated: January 29, 2015

AIWASIAN & ASSOCIATES

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By: /s/ Bruce N. Telles (as authorized 1/29/15)_______
Bruce N. Telles, Esq.
Attorneys for Defendant CENTURY
INDEMNITY COMPANY (as successor-ininterest to CCI Insurance Company, as
successor-in-interest to Insurance Company of
North America)

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ORDER
The parties having stipulated to an extension of time to and including March 16,

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2015, for the filing of a Stipulation of Dismissal in the within action, good cause

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appearing,

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IT IS SO ORDERED.
Dated: February 2, 2015

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-4STIPULATION AND REQUEST FOR LEAVE OF COURT TO EXTEND
DATE FOR FILING STIPULATION OF DISMISSAL; [PROPOSED] ORDER