The Travelers Indemnity Company of Connecticut v. Lexington Insurance Company

Filing 15

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
[e-mail]
2 EMILY G. COTTRELL, ESQ., SBN 239233
[e-mail]
3
HEROLD & SAGER
4 550 Second Street, Suite 200
Encinitas, CA 92024
5 Telephone: [phone]
Facsimile: [phone]
6
Attorneys for Lexington Insurance Company
7
UNITED STATES DISTRICT COURT
8
EASTERN DISTRICT OF CALIFORNIA

9

CASE NO.:

THE TRAVELERS INDEMNITY
COMPANY OF CONNECTICUT, a
11 Connecticut corporation,
10

12

AMENDED STIPULATION TO EXTEND
TIME TO FILE A JOINT STATUS
REPORT PURSUANT TO RULE 26(f)

Plaintiff,

13

2:16-CV-02620-JAM-DB

vs.
Complaint filed: November 2, 2016

14

LEXINGTON INSURANCE COMPANY, a
15 Delaware corporation; DOES 1-10, inclusive,
16

Defendants.

17
Plaintiff THE TRAVELERS INDEMNITY COMPANY OF CONNECTICUT (“Plaintiff”

18

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

22

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

25

26 through its registered agent for service of process;
27 ///
28 ///
1
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

1

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

4

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

8

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

10

11 and agree as follows:
STIPULATION

12
1.

13

The parties stipulate to, and request a Court order extending the deadline to file a

14 Joint Status Report to February 1, 2017.
15 ///
16 ///
17 ///
18 ///
19 ///
20 ///
21 ///
22 ///
23 ///
24 ///
25 ///
26 ///
27 ///
28 ///
2
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

2
By:

3
4
5
6
7

/s/ Ha Eun Cho
A. ERIC AGUILERA, ESQ.
[e-mail]
KARI M. MYRON, ESQ.
[e-mail]
HA EUN CHO, ESQ.
[e-mail]
Attorneys for Plaintiff, THE TRAVELERS
INDEMNITY COMPANY OF CONNECTICUT

8
9 DATED: January 13, 2017

HEROLD & SAGER

10
By:

11
12
13
14

/s/ Emily G. Cottrell
ANDREW D. HEROLD, ESQ.
[e-mail]
EMILY G. COTTRELL, ESQ.
[e-mail]
Attorneys for Defendant, LEXINGTON
INSURANCE COMPANY

15
16
17
18

IT IS SO ORDERED.
DATED:

1/17/2017

/s/ John A. Mendez
UNITED STATES DISTRICT COURT JUDGE

19
20
21
22
23
24
25
26
27
28
3
AMENDED STIPULATION TO EXTEND TIME TO FILE JOINT STATUS REPORT

CASE NO.: 2:16-CV-02620-JAM-DB