Rand v. American National Insurance Company

Filing 9

ORDER re 8 Stipulation to Answer or Otherwise Respond to Complaint. Signed by Magistrate Judge Wayne D. Brazil on 3/9/2009. (hlk, COURT STAFF) (Filed on 3/9/2009) Modified on 3/10/2009 (cjl, COURT STAFF).

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THOMAS M. HERLIHY (SBN 83615) [e-mail] SHIVANI NANDA (SBN 253891) [e-mail] WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP 525 Market Street, 17th Floor San Francisco, California 94105 Tel: [phone] Fax: [phone] Attorneys for Defendant AMERICAN NATIONAL INSURANCE COMPANY UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION DAPHNE P. RAND, by and through DEBRA J. DOLCH, as Conservator of the Person and Estate of DAPHNE P. RAND, Conservatee, on Behalf of Themselves and All Others Similarly Situated, Plaintiff, ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No.: CV09-0639 WDB

14 v. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 AMERICAN NATIONAL INSURANCE COMPANY, a Texas corporation, Defendant.

STIPULATION REGARDING DATE TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT; AND [PROPOSED] ORDER [Local Rule 6-1] Courtroom : 4 Honorable Wayne D. Brazil Filed : 02/12/09

IT IS HEREBY STIPULATED, pursuant to Local Rule 6-1, by and between plaintiff Daphne Rand, by and through Debra J. Dolch, as Conservator of the Person and Estate of Daphne P. Rand, Conservatee, on Behalf of Themselves and All Others Similarly Situated ("Plaintiff") and defendant American National Insurance Company ("Defendant"), through their attorneys of record, as follows: 1. On or about February 13, 2009, defendant American National Insurance Company

received a Notice of Lawsuit and Request For Waiver of Service of Summons regarding this action, along with a copy of the Summons and Complaint;

1 STIPULATION REGARDING DATE TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT; AND [PROPOSED] ORDER USDC NDCA Case # CV09-0639 WDB
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2. 3.

Defendant has agreed to waive service of the Summons and Complaint in this action; The parties have agreed that defendant's response to the Complaint shall be due on

or before March 27, 2009; and 4. This stipulated date for Defendant to respond to the Complaint will not alter the date

of any event or any deadline already fixed by Court order.

Date: March 6, 2009

WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP By: /s/ Thomas M. Herlihy THOMAS M. HERLIHY Attorneys for Defendant AMERICAN NATIONAL INSURANCE COMPANY BONNETT, FAIRBOURN, FRIEDMAN & BALINT, P.C.

Date: March 6, 2009

By:

/s/ Andrew S. Friedman ANDREW S. FRIEDMAN Attorneys for Plaintiff DAPHNE P. RAND

ORDER IT IS S O ORDERED.

Date: 3/9/2009

By:

UNIT ED

United States Magistrate Judge
Br ayne D. Judge W azil

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F D IS T IC T O R

2 STIPULATION REGARDING DATE TO ANSWER OR OTHERWISE RESPOND TO PLAINTIFF'S COMPLAINT; AND [PROPOSED] ORDER USDC NDCA Case # CV09-0639 WDB
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