The Travelers Indemnity Company of Connecticut v. Lexington Insurance Company
Filing
9
STIPULATION AND ORDER signed by District Judge John A. Mendez on 12/22/2016 ORDERING the defendant to respond to the 1 Complaint by 1/10/2017. (Michel, G.)
1 ANDREW D. HEROLD, ESQ., SBN 178640
aherold@heroldsagerlaw.com
2 EMILY G. COTTRELL, ESQ., SBN 239233
ecottrell@heroldsagerlaw.com
3
HEROLD & SAGER
4 550 Second Street, Suite 200
Encinitas, CA 92024
5 Telephone: (760) 487-1047
Facsimile: (760) 487-1067
6
Attorneys for Lexington Insurance Company
7
8
UNITED STATES DISTRICT COURT
9
EASTERN DISTRICT OF CALIFORNIA
10 THE TRAVELERS INDEMNITY
11 COMPANY OF CONNECTICUT, a
Connecticut organization,
12
Plaintiffs,
13
vs.
14
CASE NO.:
15 LEXINGTON INSURANCE COMPANY, a
Delaware corporation; DOES 1-10, inclusive,
16
Defendants.
17
Complaint served:
New response date:
2:16-CV-02620-JAM-DB
STIPULATION TO EXTEND TIME TO
FILE A RESPONSIVE PLEADING TO
INITIAL COMPLAINT (SECOND
REQUEST)
November 16, 2016
January 10, 2016
18
19
Plaintiff THE TRAVELERS INDEMNITY COMPANY OF CONNECTICUT (“Plaintiff”)
20 and Defendant LEXINGTON INSURANCE COMPANY (“Defendant”) (together, Plaintiff and
21 Defendant may be referred to as the “Parties”) hereby submit the following Stipulation to Extend
22 Time to File a Responsive Pleading to the Complaint in the above-captioned action.
23
WHEREAS, Travelers filed a complaint on November 2, 2016 (“Complaint”), in the United
24 States District Court, Eastern District of California as case number 2:16-CV-02620-JAM-DB
25 naming Lexington as the Defendant;
26
WHEREAS, on or about November 16, 2016, Plaintiff served Defendant with the complaint
27 through its registered agent for service of process;
28 ///
1
STIPULATION TO EXTEND TIME TO FILE RESPONSIVE PLEADING (SECOND REQUEST)
CASE NO.: 2:16-CV-02620-JAM-DB
1
WHEREAS, the Parties have agreed to extend the time for Defendant to file a responsive
2 pleading to the Complaint until January 10, 2017;
3
WHEREAS, while the Court has granted one extension to file a responsive pleading until
4 December 22, 2016, certain facts have recently developed which may impact the Parties’ positions
5 on the claims at issue in the Complaint and which may lead to early resolution of certain claims in
6 the Complaint;
7
NOW, THEREFORE, Plaintiff and Defendant, by and through their respective counsel of
8 record, hereby stipulate to allow for an extension of time for Defendant to file a responsive pleading
9 until January 10, 2017.
10 DATED: December 22, 2016
THE AGUILERA LAW GROUP, APLC
11
12
By: /s/ Kari M. Myron
A. ERIC AGUILERA, ESQ.
eaguilera@aguileragroup.com
Kari M. Myron, ESQ.
kmyron@aguileragroup.com
Attorneys for Plaintiff, THE TRAVELERS
INDEMNITY COMPANY OF CONNECTICUT
13
14
15
16
17
18 DATED: December 22, 2016
HEROLD & SAGER
19
20
By:
21
22
23
24
25
/s/ Emily G. Cottrell
ANDREW D. HEROLD, ESQ.
aherold@heroldsagerlaw.com
EMILY G. COTTRELL, ESQ.
ecottrell@heroldsagerlaw.com
Attorneys for Defendant, LEXINGTON
INSURANCE COMPANY
IT IS SO ORDERED.
26 DATED:
December 22, 2016
/s/ JOHN A. MENDEZ
UNITED STATES DISTRICT JUDGE
27
28
2
STIPULATION TO EXTEND TIME TO FILE RESPONSIVE PLEADING (SECOND REQUEST)
CASE NO.: 2:16-CV-02620-JAM-DB
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