National Union Fire Insurance Company of Pittsburgh, PA v. Payless Shoe Source, Inc. et al

Filing 54

STIPULATION AND ORDER re 40 MOTION TO ENJOIN DEFENDANTS FROM PROSECUTING SIMILAR LITIGATION IN KANSAS Stipulation to Extend Time to File Reply Brief filed by National Union Fire Insurance Company of Pittsburgh, PA. Plaintiff's reply due 7/3/12. Signed by Judge Edward M. Chen on 7/2/12. (bpf, COURT STAFF) (Filed on 7/2/2012)

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EDWARDS WILDMAN PALMER LLP
Clinton J. McCord (CA Bar No. 204749)
9665 Wilshire Boulevard, Suite 200
Beverly Hills, CA 90212
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorney for Plaintiff
NATIONAL UNION FIRE INSURANCE COMPANY OF
PITTSBURGH, PA.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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NATIONAL UNION FIRE
INSURANCE COMPANY OF
PITTSBURGH, PA.,

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Plaintiff,

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vs.
PAYLESS SHOE SOURCE, INC. et
al.

Case No. CV-11-01892-EMC
STIPULATION TO EXTEND TIME TO
FILE REPLY BRIEF; PROPOSED
ORDER
Date:
Time:
Place:

July 19, 2012
1:30 p.m.
San Francisco Courthouse
Courtroom 5
450 Golden Gate Avenue
San Francisco, CA 94102

Defendants.

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STIPULATION TO EXTEND TIME TO
FILE REPLY BRIEF; PROPOSED
ORDER

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Case No. CV-11-01892-EMC

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STIPULATION
Pursuant to L.R. 6-2, the parties hereby stipulate to extend the time for Plaintiff to file its
reply brief in support of Motion to Enjoin Defendants from Prosecuting Similar Litigation in
Kansas, filed on June 8, 2012 (ECF No. 40). The reply brief is currently due today, June 29,
2012. However, due to the unavailability of Plaintiff’s principal to review the brief, Plaintiff
requests that the Court allow Plaintiff to file its reply brief on Tuesday, July 3rd. (See
concurrently-filed Declaration of Clinton J. McCord). Defendants have agreed to this relief.
The hearing for the motion is currently set for July 19th at 1:30 p.m. The requested relief should
not affect the hearing or otherwise affect the schedule for the case.
WHEREFORE, the parties, through their counsel, hereby stipulate to allow Plaintiff to
file its reply brief in support of Motion to Enjoin Defendants from Prosecuting Similar Litigation
in Kansas on July 3, 2012, and request an Order from the Court allowing same.
Dated: June 29, 2012
Defendant Payless Shoe Source, Inc.
Defendant Collective Brands, Inc.

Plaintiff National Union Fire Insurance
Company of Pittsburgh, PA

By: /s/ _Sverker K. Hogberg
SULLIVAN & CROMWELL LLP
Robert Andrew Sacks
([e-mail])
1888 Century Park East
Los Angeles, CA 90067

By: /s/ Clinton J. McCord
EDWARDS WILDMAN PALMER LLP
Clinton J. McCord
([e-mail])
9665 Wilshire Boulevard, Suite 200
Los Angeles, CA 90212
Telephone [phone]
Facsimile [phone]

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Sverker K. Hogberg
([e-mail])
1870 Embarcadero Road
Palo Alto, CA 94303
Telephone [phone]
Facsimile [phone]

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Attorneys for Defendants

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Attorneys for Plaintiff

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STIPULATION TO EXTEND TIME TO
FILE REPLY BRIEF; PROPOSED
ORDER

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Case No. CV-11-01892-EMC

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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7/2
DATED: ______________, 2012

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STIPULATION TO EXTEND TIME TO
FILE REPLY BRIEF; PROPOSED
ORDER

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Case No. CV-11-01892-EMC