Axis Reinsurance Company v. Telekenex, Inc. et al

Filing 59

STIPULATION AND ORDER Extending Time for Axis Reinsurance Company to Respond to Straitshot's Counterclaim. (tdm, COURT STAFF) (Filed on 11/14/2012)

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TROUTMAN SANDERS LLP
Terrence R. McInnis, Bar No. 155416
[e-mail]
Ross Smith, Bar No. 204018
[e-mail]
5 Park Plaza, Suite 1400
Irvine, CA 92614-2545
Telephone:
949.622.2700
Facsimile:
949.622.2739
Attorneys for Plaintiff
AXIS Reinsurance Company

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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IRVINE, CA 92614-2545

5 PARK PLAZA, SUITE 1400

TROUTMAN SANDERS LLP

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AXIS REINSURANCE COMPANY,

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Plaintiff,

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v.
TELEKENEX, INC.; ANTHONY ZABIT;
KAREN SALAZAR; BRANDON CHANEY;
DEANNA CHANEY; MARK PRUDELL;
JOY PRUDELL; MARK RADFORD; NIKKI
RADFORD; JOSHUA SUMMERS; JULIA
SUMMERS; IXC HOLDINGS, INC.;
STRAITSHOT COMMUNICATIONS, INC.;
STRAITSHOT RC, LLC,

Case No. 3:12-cv-02979-SC
STIPULATION EXTENDING TIME
OF AXIS REINSURANCE COMPANY
TO RESPOND TO STRAITSHOT’S
COUNTERCLAIM
[Civil Local Rule 6-1(a)]

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Defendant.
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WHEREAS, on June 8, 2012, Plaintiff AXIS Reinsurance Company (“AXIS”) filed a

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Complaint in the above-captioned Case No. 3:12-cv-02979-SC and, on July 27, 2012, filed a First

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Amended Complaint.
WHEREAS, Straitshot Communications, Inc. and Straitshot RC, LLC (collectively,

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“Straitshot”) filed an Answer and Counterclaim on September 5, 2012, which was served on

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AXIS electronically, such that pursuant to Federal Rules of Civil Procedure, Rules 12(a)(1),

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5(b)(E), and 6(d), AXIS’s response to Straitshot’s Counterclaim was initially due October 1,

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2012.
Case No. 3:12-cv-02979-SC

STIPULATION EXTENDING TIME TO RESPOND TO
COUNTERCLAIM

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WHEREAS, Straitshot previously agreed to extend the time for AXIS to respond to the
Counterclaim to and including November 12, 2012.

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WHEREAS, AXIS and Straitshot stipulate and agree to further extend the time for AXIS
to respond to the Counterclaim for another two-weeks – to and including November 26, 2012.

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WHEREAS, the extension of time will not alter the date of any event or deadline already
fixed by Court order.

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WHERAS, by entering into this stipulation, AXIS and Straitshot do not waive any claims
or defenses.

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STIPULATION

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NOW THEREFORE, it is agreed and stipulated that: Pursuant to Rule 6-1(a) of the Civil
Local Rules of the United States District Court for the Northern District of California, AXIS’s
deadline to file a responsive pleading and/or motion to Straitshot’s Counterclaim in the abovecaptioned action is extended to November 26, 2012.

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Respectfully submitted,

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Dated: November 9, 2012

TROUTMAN SANDERS LLP

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BY:
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Dated: November 9, 2012

R NIA

S

ER

H

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FO

Judge S

RT

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onti

amuel C

NO

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ERED

O ORD

IT IS S

MASSEY & GAIL LLP
BY:

/s/ Leonard A. Gail
Leonard A. Gail
Attorneys for Defendants and
Counterclaimants STRAITSHOT
COMMUNICATIONS, INC., and
STRAITSHOT RC, LLC

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ISTRIC
ES D
TC
AT
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RT
U
O

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/s/ Terrence R. McInnis
Terrence R. McInnis
Attorneys for Plaintiff
AXIS REINSURANCE COMPANY

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UNIT
ED

IRVINE, CA 92614-2545

5 PARK PLAZA, SUITE 1400

TROUTMAN SANDERS LLP

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D IS T IC T O
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Filer’s Attestation: Pursuant to Local Rule 5-1(i)(3) regarding signatures, Ross Smith hereby
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attests that concurrence in the filing of this document has been obtained.
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Case No. 3:12-cv-02979-SC

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STIPULATION EXTENDING TIME TO
RESPOND TO COUNTERCLAIM