The Travelers Indemnity Company of Connecticut v. Lexington Insurance Company

Filing 28

STIPULATION and ORDER signed by District Judge John A. Mendez on 7/25/18, ORDERING that the deadline to file settlement/dismissal documents is CONTINUED to 8/27/18. (Kastilahn, A)

1 ANDREW D. HEROLD, ESQ., SBN 178640
[e-mail]
2 EMILY G. COTTRELL, ESQ., SBN 239233
[e-mail]
3
DREW P. ROSELL, ESQ., SBN 306524
4 [e-mail]
HEROLD & SAGER
5 550 Second Street, Suite 200
Encinitas, CA 92024
6 Telephone: [phone]
7 Facsimile: [phone]
8 Attorneys for Lexington Insurance Company
9

UNITED STATES DISTRICT COURT

10

EASTERN DISTRICT OF CALIFORNIA

11 THE TRAVELERS INDEMNITY
COMPANY OF CONNECTICUT, a
12 Connecticut corporation,
13
14

CASE NO.: 2:16-CV-02620-JAM-DB
STIPULATION AND
ORDER TO CONTINUE DISMISSAL
DATE

Plaintiff,
vs.

Complaint filed: November 2, 2016

15
LEXINGTON INSURANCE COMPANY, a
16 Delaware corporation; DOES 1-10, inclusive,
17

Defendants.

18
19

Plaintiff

THE

TRAVELERS

INDEMNITY

COMPANY

OF

CONNECTICUT

20 (“Travelers”) and Defendant LEXINGTON INSURANCE COMPANY (“Lexington”) hereby
21 submit the following Stipulation, pursuant to Local Rule 160 of the United States District Court,
22 Eastern District of California, to continue the July 27, 2018 deadline to file settlement/dismissal
23 documents, by approximately thirty (30) days to August 27, 2018, for good cause shown as follows:
24

WHEREAS, counsel for Travelers filed a Notice of Settlement of the Entire Action on April

25 24, 2018, advising the Court that the parties had settled the case, were preparing settlement and
26 dismissal documentation, and requested the Court set an order to show cause regarding dismissal no
27 later than 90 days from the date of the filing;
28

WHEREAS, on April 24, 2018, the Court issued a minute order, setting July 27, 2018 as the
1
STIPULATION TO CONTINUE DISMISSAL DATE

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

1 deadline for counsel to file settlement/dismissal documents;
2

WHEREAS, the parties have worked diligently to prepare the settlement agreement and

3 expect that this will be accomplished in the next 30 days. A brief thirty (30) day continuance of the
4 July 27, 2018 deadline to file settlement/dismissal documents will not prejudice the parties, and
5 there are no additional hearing dates or deadlines before the Court in this action;
6

NOW THEREFORE, the parties, by and through their respective counsel of record, stipulate

7 and agree as follows:
8
9

STIPULATION
The parties stipulate to and request a Court order continuing the dismissal deadline by

10 approximately thirty (30) days, from July 27, 2018 to August 27, 2018.
11
12 DATED: July 25, 2018

THE AGUILERA LAW GROUP, APLC

13
/s/Ha Eun Cho, Esq. (as authorized on July 25, 2018).
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

14
15
16
17
18
19 DATED: July 25, 2018

HEROLD & SAGER

20

/s/Drew P. Rosell, Esq.
ANDREW D. HEROLD, ESQ.
[e-mail]
EMILY G. COTTRELL, ESQ.
[e-mail]
DREW P. ROSELL, ESQ.
[e-mail]
Attorneys for Defendant, LEXINGTON
INSURANCE COMPANY

21
22
23
24
25

GOOD CAUSE HAVING BEEN SHOWN, IT IS SO ORDERED.

26
27

DATED: 7/25/2018
7/25/
7/25/2018
28

/s/ John A. Mendez
UNITED STATES DISTRICT COURT JUDGE
/s/ John A. Mendez________________________
2

STIPULATION TO CONTINUE DISMISSAL DATE

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