The Guardian Life Insurance Company of America v. Bartholomew et al

Filing 13

STIPULATION and ORDER signed by District Judge John A. Mendez on 6/23/17, ORDERING that Defendants LaTour Bartholomew and Cotis CharlesChilds shall have an extension of time to file their respective responsive pleadings to the Complaint in Interpleader by no later than 7/21/2017. (Kastilahn, A)

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Michael B. Bernacchi (SBN 163657)
E-mail: [e-mail]
Keiko J. Kojima (SBN 206595)
E-mail: [e-mail]
BURKE, WILLIAMS & SORENSEN, LLP
444 South Flower Street, Suite 2400
Los Angeles, CA 90071-2953
Tel: [phone]; Fax: [phone]
Attorneys for Plaintiff
The Guardian Life Insurance Company of America

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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THE GUARDIAN LIFE INSURANCE
COMPANY OF AMERICA,
Plaintiff,
v.
LATOUR BARTHOLOMEW, an
individual; COTIS CHARLES
CHILDS, an individual; and DOES 1 to
10, inclusive,

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Case No. 2:17-cv-00227-JAM-KJN
STIPULATION FOR EXTENSION
OF TIME FOR DEFENDANTS TO
FILE RESPONSIVE PLEADINGS
TO THE COMPLAINT IN
INTERPLEADER; ORDER
Complaint served: 02/08/2017
Current Response Date: 04/10/2017
New Response Date: 07/21/2017

Defendants.

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Plaintiff The Guardian Life Insurance Company of America (“Guardian”)
and Defendants Latour Bartholomew (“Bartholomew”) and Cotis Charles Childs
(“Childs”) (collectively “Defendants”), through their respective counsel, hereby
stipulate and agree as follows:
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Both Defendant Bartholomew and Defendant Childs have agreed to

accept service by waiver of service of summons. The service date for both
defendants is February 8, 2017, with responsive pleading due on April 10, 2017.
However, Defendants have agreed to a settlement and are seeking approval through
their pending probate court action. Plaintiff Guardian has agreed to stipulate to

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B URKE , W ILLIAMS &
S ORENSEN , LLP
ATTORNEYS AT LAW
LOS ANGELES

LA #4851-1709-1658 v1

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STIPULATION FOR EXTENSION OF TIME TO
FILE RESPONSIVE PLEADINGS TO THE
COMPLAINT IN INTERPLEADER

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the extension of Defendants’ responsive pleading to the new requested deadline of

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July 21, 2017.

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2.

Guardian and Defendants hereby stipulate and agree, subject to the

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Court’s approval, that each Defendant shall have an extension up to and including

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July 21, 2017, within which to file responsive pleadings to the Complaint in

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Interpleader.

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IT IS SO STIPULATED.

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Dated: June ___, 2017

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Burke, Williams & Sorensen, LLP
Michael B. Bernacchi
Keiko J. Kojima

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By: /s/ Keiko J. Kojima
Keiko J. Kojima
Attorneys for Plaintiff
The Guardian Life Insurance Company of
America

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Dated: June ___, 2017

Law Offices of G. Cat Stokes

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By:

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G. Cat Stokes
Attorneys for Defendant
Latour Bartholomew

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Dated: June ___, 2017

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Law Offices of Linda Dankman
By:
Linda Dankman
Attorneys for Defendant
Cotis Charles Childs

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B URKE , W ILLIAMS &
S ORENSEN , LLP
ATTORNEYS AT LAW
LOS ANGELES

LA #4851-1709-1658 v1

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STIPULATION FOR EXTENSION OF TIME TO
FILE RESPONSIVE PLEADINGS TO THE
COMPLAINT IN INTERPLEADER

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ORDER
Having considered the parties’ stipulation, and good cause appearing, IT IS

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HEREBY ORDERED that Defendants LaTour Bartholomew and Cotis Charles

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Childs shall have an extension of time to file their respective responsive pleadings

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to the Complaint in Interpleader by no later than July 21, 2017.

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IT IS SO ORDERED.

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Dated: 6/23/2017

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/s/ John A. Mendez____________
Honorable John A. Mendez
United States District Court Judge

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B URKE , W ILLIAMS &
S ORENSEN , LLP
ATTORNEYS AT LAW
LOS ANGELES

LA #4851-1709-1658 v1

-3-

STIPULATION FOR EXTENSION OF TIME TO
FILE RESPONSIVE PLEADINGS TO THE
COMPLAINT IN INTERPLEADER