Camp Richardson Resort, Inc. v. Philadelphia Indemnity Insurance Company

Filing 8

SECOND STIPULATION and ORDER 7 for extension of time signed by District Judge Troy L. Nunley on 7/8/2015. Defendant Philadelphia may have up to and including 7/17/2015 to file an Answer or otherwise respond to Complaint. (Marciel, M)

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JAMES C. NIELSEN (111889)
[e-mail]
CHRISTINE B. CUSICK (280646)
[e-mail]
NIELSEN, HALEY & ABBOTT LLP
100 Smith Ranch Road, Suite 350
San Rafael, California 94903
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant,
PHILADELPHIA INDEMNITY INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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CAMP RICHARDSON RESORT, INC.,
Plaintiff,
v.

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PHILADELPHIA INDEMNITY
INSURANCE COMPANY;
Defendant.

Civil Action No.: 2:15-CV-01101-TLNAC
SECOND STIPULATION TO EXTEND
TIME TO RESPOND TO COMPLAINT
(L.R. 144) AND ORDER
HONORABLE
TROY L. NUNLEY

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TO THE CLERK OF THE ABOVE-ENTITLED COURT:
On June 16, 2015, the parties filed a stipulation pursuant to Eastern District Local

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Rule 144 (Fed. Rules Civ. Proc., rule 6), stating that Defendant Philadelphia Indemnity

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Insurance Company may have up to and including July 7, 2015, to file an answer or

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otherwise respond to the complaint. That was the first extension of time in this case and

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extended the time to file by 20 days.
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SECOND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT

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The parties now seek the Court’s approval to stipulate that Philadelphia may have up

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to and including July 17, 2015, to file an answer or otherwise respond to the complaint.

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This is the second extension of time in this case.

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Philadelphia seeks this extension because it intends to file a motion under Rule

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12b(6) and the complexity of the issues is such that defense counsel has not been able to

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complete its motion under the original two-week extension and will need another ten days

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to do so. The additional time is additionally justified because the two defense attorneys

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working on this matter have encountered several short-term legal emergencies on other

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engagements that have prevented them from devoting full time to the preparing of their

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initial motion here and their time has been further reduced due to a partner in their firm

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taking sabbatical, creating a crush of work. The Plaintiff does not object to Philadelphia’s

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request for a second extension.

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Dated: July 6, 2015

BANKS & WATSON

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By:

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/s/
ROBERTA LINDSEY SCOTT
Attorneys for Plaintiff
CAMP RICHARDSON RESORT, INC.

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Dated: July 6, 2015

NIELSEN, HALEY & ABBOTT LLP

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By:

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/s/
CHRISTINE B. CUSICK
Attorneys for Defendant
PHILADELPHIA INDEMNITY INSURANCE COMPANY

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In accordance with the foregoing stipulation IT IS SO ORDERED.

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Dated: July 8, 2015

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Troy L. Nunley
United States District Judge

SECOND STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT