Illinois Union Insurance Company v. Intuitive Surgical, Inc.

Filing 129

STIPULATION AND ORDER re 127 STIPULATION WITH PROPOSED ORDER re: EXTENDING TIME TO FILE OPPOSITION AND REPLY BRIEFS (PLAINTIFF INSURERS MOTIONS FOR SUMMARY JUDGMENT RE: RESCISSION); filed by Illinois Union Insurance Company. Signed by Judge Jon S. Tigar on March 16, 2016. (wsn, COURT STAFF) (Filed on 3/16/2016)

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Thomas M. Jones, Pro Hac Vice
Charles E. Wheeler, CSB No. 82915
COZEN O'CONNOR
501 West Broadway, Suite 1610
San Diego, CA 92101
Telephone: [phone]
Facsimile: 619.234.7831
[e-mail]
[e-mail]
Attorneys for Plaintiff
Illinois Union Insurance Company
UNITED STATES DISTRICT COURT, NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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ILLINOIS UNION INSURANCE COMPANY,
an Illinois corporation,

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Plaintiff,
v.
INTUITIVE SURGICAL, INC., a Delaware
corporation,
Defendant.

Case No.: 3:13-cv-04863-JST
JOINT STIPULATION TO EXTEND
TIME TO FILE OPPOSITION AND
REPLY BRIEFS (PLAINTIFF
INSURERS’ MOTIONS FOR
SUMMARY JUDGMENT RE:
RESCISSION); and
[PROPOSED] ORDER.

_______________________________________
AND CONSOLIDATED ACTIONS

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Plaintiffs Illinois Union Insurance Company (“Illinois Union”) and Navigators Specialty

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Insurance Company (“Navigators”) (collectively the “Insurers”) and Defendant Intuitive Surgical,

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Inc. (“Intuitive”) jointly stipulate, pursuant to Civil Local Rules 6-1(b), 6-2, and 7-12, to extend the

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time to file any opposition and reply briefs regarding the Insurers’ summary judgment motions on

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rescission (the “Motions”).

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WHEREAS, on March 15, 2016, Illinois Union and Navigators filed and served their Motions
and set the Motions for hearing on May 26, 2016;

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JOINT STIP. TO EXTEND TIME RE: INSURERS’ MSJS

CASE NO. 3:13-CV-04863-JST

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WHEREAS, as currently scheduled, Intuitive’s oppositions to the Insurers’ Motions would be
due March 29, 2016 and the Insurers’ replies would be due April 5, 2016;
WHEREAS, all parties have agreed to a mutual one-week extension for both Intuitive’s
oppositions and the Insurers’ replies;
Now therefore, the parties, through their undersigned counsel, hereby stipulate as follows:
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That the deadline for filing any opposition(s) to the Insurers’ Motions be extended by

one week to April 5, 2016; and
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That the deadline for filing any reply(ies) in support of the Insurers’ Motions be

extended by one week to April 19, 2016.

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DATED: March 16, 2016

COZEN O’CONNOR
By:
/s/ Charles E. Wheeler
Attorneys for Plaintiff ILLINOIS UNION
INSURANCE COMPANY

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HINSHAW & CULBERTSON LLP

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By: ____________/s/ John S. Pierce_______________
Attorneys for Plaintiff NAVIGATORS SPECIALTY
INSURANCE COMPANY

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SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP
By:
/s/ James P. Schaefer
Attorneys for Defendant INTUITIVE SURGICAL, INC.

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Pursuant to Civil Local Rule 5-1(i), the filer attests that concurrence in the filing of this
document has been obtained from the signatories above.

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/s/ Charles E. Wheeler

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JOINT STIP. TO EXTEND TIME RE: INSURERS’ MSJS

CASE NO. 3:13-CV-04863-JST

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1. The deadline for filing any opposition(s) to the Insurers’ Motions for summary judgment on
rescission be extended by one week to April 5, 2016; and
2. The deadline for filing any reply(ies) in support of the Insurers’ Motions for summary
judgment on rescission be extended by one week to April 19, 2016.
IT IS SO ORDERED.

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UNIT
ED

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The Honorable Jon. S. Tigar
United States District Court Judge

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APPRO

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DATED: March 16, 2016

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HEREBY ORDERED THAT:

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PURSUANT TO THE FOREGOING STIPULATION OF THE PARTIES, IT IS

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[PROPOSED] ORDER

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[PROPOSED] ORDER EXTENDING TIME RE: INSURERS’ MSJS

CASE NO. 3:13-CV-04863-JST