Union Pacific Railroad Company v. Ace American Insurance Company, et al

Filing 12

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr on 10/5/2017 EXTENDING Continental Casualty Co.'s deadline to file a responsive pleading to plaintiff's complaint. Responsive pleading due by 10/17/17. (Donati, J)

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Sherman C. Lee (SBN 145765)
CNA COVERAGE LITIGATION GROUP
555 – 12th Street
Suite 600
Oakland, CA 94607
Telephone: [phone]
Facsimile: 510.645.2323
E-Mail:
[e-mail]

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Attorneys for Defendant Continental Casualty Company

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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UNION PACIFIC RAILROAD COMPANY, a
Delaware corporation,

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Plaintiff,

Case No. 2:17-cv-01860-MCE-AC
STIPULATION TO EXTEND TIME TO
RESPOND TO COMPLAINT; ORDER

vs.
ACE AMERICAN INSURANCE COMPANY,
a Pennsylvania corporation, dba CHUBB;
CONTINENTAL CASUALTY COMPANY,
RENZENBERGER, INC.,

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Defendants.

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Plaintiffs UNION PACIFIC RAILROAD COMPANY (“Union Pacific”) and defendant

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CONTINENTAL CASUALTY COMPANY (“Continental Casualty”), by and through their

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attorneys of record in this case, hereby stipulate and agree that:

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WHEREAS, Union Pacific filed its Complaint in this action on September 7, 2017;

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WHEREAS, Continental Casualty’s responsive pleading is presently due on October 3,

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2017;
WHEREAS, Continental Casualty requested and Union Pacific agreed to a brief 14 day
extension of time to the Complaint;

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WHEREAS, the extension of time will not alter the date of any event or other deadline;

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WHEREAS, no extension of time has been previously sought or requested;
-1STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT

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WHEREAS, Local Rule 144(a) of the United State District Court for the Eastern District of

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California provides that the parties may stipulate to extend the time for responding to a complaint

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without leave of Court so long as all parties affected by the extension consent and the extension is no

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longer than 28 days;

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NOW, THEREFORE, IT IS HEREBY STIPULATED by and between the parties, through

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their respective counsel, that Continental Casualty shall file its responsive pleading by October 17,

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2017.

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IT IS SO STIPULATED.
Dated: September 29, 2017

MURPHY, CAMPBELL, ALLISTON & QUINN

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By:

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/s/ Suzanne M. Nicholson
Suzanne M. Nicholson
Attorneys for Plaintiff
UNION PACIFIC RAILROAD COMPANY

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Dated: September 29, 2017

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CNA COVERAGE LITIGATION GROUP

By:

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/s/ Sherman C. Lee
Sherman C. Lee
Attorney for Defendant
Continental Casualty Company

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SIGNATURE CERTIFICATION

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I hereby attest that all other signatories listed, and on whose behalf this filing is submitted,

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concur in the filing’s content and have authorized the filing.

Dated: September 29, 2017

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By:

/s/ Sherman C. Lee
Sherman C. Lee

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-2STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT

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ORDER
The Court, having duly considered the parties’ stipulation set forth above, and good cause
appearing, orders as follows:
Continental Casualty Co.’s deadline to file a responsive pleading to plaintiff’s Complaint is

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extended to October 17, 2017.

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IT IS SO ORDERED.

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Dated: October 5, 2017

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-3STIPULATION EXTENDING TIME TO RESPOND TO COMPLAINT