The Travelers Indemnity Company of Connecticut v. Lexington Insurance Company
Filing
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STIPULATION and ORDER signed by District Judge John A. Mendez on 1/17/2017 ORDERING that the deadline to file a Joint Status Report is EXTENDED to 2/1/2017. (Jackson, T)
1 ANDREW D. HEROLD, ESQ., SBN 178640
aherold@heroldsagerlaw.com
2 EMILY G. COTTRELL, ESQ., SBN 239233
ecottrell@heroldsagerlaw.com
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HEROLD & SAGER
4 550 Second Street, Suite 200
Encinitas, CA 92024
5 Telephone: (760) 487-1047
Facsimile: (760) 487-1067
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Attorneys for Lexington Insurance Company
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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CASE NO.:
THE TRAVELERS INDEMNITY
COMPANY OF CONNECTICUT, a
11 Connecticut corporation,
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AMENDED STIPULATION TO EXTEND
TIME TO FILE A JOINT STATUS
REPORT PURSUANT TO RULE 26(f)
Plaintiff,
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2:16-CV-02620-JAM-DB
vs.
Complaint filed: November 2, 2016
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LEXINGTON INSURANCE COMPANY, a
15 Delaware corporation; DOES 1-10, inclusive,
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Defendants.
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Plaintiff THE TRAVELERS INDEMNITY COMPANY OF CONNECTICUT (“Plaintiff”
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19 or “Travelers”) and Defendant LEXINGTON INSURANCE COMPANY (“Lexington”), hereby
20 submit the following Stipulation to Extend Time to File a Joint Status Report pursuant to Rule 26(f)
21 in the above-captioned action.
WHEREAS, Plaintiff filed a complaint on November 2, 2016 (“Complaint”), in the United
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23 States District Court, Eastern District of California as case number 2:16-CV-02620-JAM-DB
24 naming Lexington as a defendant;
WHEREAS, on or about November 16, 2016, Plaintiff served Lexington with the Complaint
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26 through its registered agent for service of process;
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AMENDED STIPULATION TO EXTEND TIME TO FILE JOINT STATUS REPORT
CASE NO.: 2:16-CV-02620-JAM-DB
WHEREAS, the parties agreed, and the Court ordered, to extend the time for Lexington to
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2 file a responsive pleading to the Complaint until January 10, 2017, and Lexington filed its
3 responsive pleading timely on January 10, 2017;
WHEREAS, pursuant to the Court’s Order Requiring Joint Status Report, dated November
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5 3, 2016, the Court ordered the parties to file a Joint Status Report sixty (60) days after service of the
6 Complaint, which would fall on January 17, 2017, only seven (7) calendar days after the filing of
7 Lexington’s responsive pleading;
WHEREAS, the parties request a short extension of time to allow the parties to properly
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9 meet and confer and prepare a comprehensive Joint Status Report for submission to the Court.
NOW THEREFORE, the parties, by and through their respective counsel of record, stipulate
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11 and agree as follows:
STIPULATION
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1.
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The parties stipulate to, and request a Court order extending the deadline to file a
14 Joint Status Report to February 1, 2017.
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AMENDED STIPULATION TO EXTEND TIME TO FILE JOINT STATUS REPORT
CASE NO.: 2:16-CV-02620-JAM-DB
1 DATED: January 13, 2017
THE AGUILERA LAW GROUP, APLC
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By:
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/s/ Ha Eun Cho
A. ERIC AGUILERA, ESQ.
eaguilera@aguileragroup.com
KARI M. MYRON, ESQ.
kmyron@aguileragroup.com
HA EUN CHO, ESQ.
hcho@aguileraagroup.com
Attorneys for Plaintiff, THE TRAVELERS
INDEMNITY COMPANY OF CONNECTICUT
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9 DATED: January 13, 2017
HEROLD & SAGER
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By:
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/s/ Emily G. Cottrell
ANDREW D. HEROLD, ESQ.
aherold@heroldsagerlaw.com
EMILY G. COTTRELL, ESQ.
ecottrell@heroldsagerlaw.com
Attorneys for Defendant, LEXINGTON
INSURANCE COMPANY
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IT IS SO ORDERED.
DATED:
1/17/2017
/s/ John A. Mendez
UNITED STATES DISTRICT COURT JUDGE
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AMENDED STIPULATION TO EXTEND TIME TO FILE JOINT STATUS REPORT
CASE NO.: 2:16-CV-02620-JAM-DB
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