Lincoln National Life Insurance Company, The v. Pacific Specialty Insurance Company et al

Filing 25

ORDER adopting 24 STIPULATION WITH PROPOSED ORDER TO EXTEND DEADLINE TO RESPOND TO COMPLAINT. Deadline to respond to Complaint for Declaratory Relief: 4/30/2014. Case Management Statement due by 5/6/2014. Case Management Conference rescheduled for 5/13/2014 02:00 PM in Courtroom 2, 17th Floor, San Francisco. Signed by Judge William H. Orrick on 03/27/2014. (jmdS, COURT STAFF) (Filed on 3/27/2014)

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JOSEPH P. MCMONIGLE (SBN 66811)
GLEN R. OLSON (SBN 111914)
LONG & LEVIT, LLP
465 California Street, Suite 500
San Francisco, California 94104
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]

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LAWRENCE A. JACOBSON (SBN 57393)
SEAN M. JACOBSON (SBN 227241)
COHEN AND JACOBSON, LLP
900 Veterans Boulevard, Suite 600
Redwood City, California 94063
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]

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Attorneys for Defendant Ann Morrical

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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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Case No. 3:14-cv-00039

THE LINCOLN NATIONAL LIFE
INSURANCE COMPANY, an Indiana
corporation;

SECOND STIPULATION BETWEEN
PLAINTIFF THE LINCOLN
NATIONAL LIFE INSURANCE
COMPANY AND DEFENDANT ANN
MORRICAL TO EXTEND DEADLINE
TO RESPOND TO COMPLAINT;
ORDER THEREON

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Plaintiff,
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v.
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PACIFIC SPECIALTY INSURANCE
COMPANY, a California corporation; ANN
MORRICAL, an individual; MICHAEL
MCGRAW, an individual; JOHN
MCGRAW, an individual; JESSE
ROGERS, an individual; KEONI
SCHWARTZ, an individual; GENE
BECKER, an individual; JOHN CHU, an
individual; BRIAN COHEN, an individual,
and DOES 1-20, inclusive,
Defendants.

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SECOND STIPULATION TO EXTEND DEADLINE
TO RESPOND TO COM PLAINT; ORDER

Case No. 3:14-cv-00039

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Plaintiff The Lincoln National Life Insurance Company and Defendant Ann Morrical,

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through their respective counsel of record, hereby stipulate and agree that the deadline for Ann

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Morrical to respond to the Complaint for Declaratory Relief is extended from March 3, 2014 to

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April 30, 2014. The parties make this Stipulation on the basis that they are engaged in settlement

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discussions; that draft settlement documents have been exchanged and are being reviewed; and

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the parties believe that a resolution of this matter has been reached, subject to final

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documentation, that will obviate the need to respond to the Complaint.

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The Parties disclose that they have previously entered into one similar stipulation that was
approved by the Court on February 11, 2014. The Parties further represent that a scheduling

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conference is presently scheduled for April 22, 2014, and the Parties respectfully request that the

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scheduling conference be continued to the first available date after April 30, 2014.

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Respectfully submitted.
Dated: March 24, 2014

COHEN AND JACOBSON, LLP

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By

/s/

Lawrence A. Jacobson

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Joseph P. McMonigle (SBN 66811)
Glen R. Olson (SBN 111914)
Long & Levit, LLP
465 California Street, Suite 500
San Francisco, California 94104
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]

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Lawrence A. Jacobson (SBN 57393)
Sean M. Jacobson (SBN 227241)
Cohen and Jacobson, LLP
900 Veterans Boulevard, Suite 600
Redwood City, California 94063
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]

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Attorneys for Defendant Ann Morrical
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[Signatures and Order continued on next page]

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SECOND STIPULATION TO EXTEND DEADLINE
TO RESPOND TO COM PLAINT; ORDER

Case No. 3:14-cv-00039

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Dated: March 24, 2014

BALLARD SPAHR LLP

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By

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Alan Petlak
Ethan Chernin
BALLARD SPAHR LLP
Attorneys for Plaintiff

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/s/

Alan Petlak

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ORDER
The Court having read and considered the foregoing Stipulation, and good cause

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appearing, it is hereby ordered that the Stipulation is APPROVED, and the deadline for Ann

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Morrical to respond to the Complaint for Declaratory Relief is extended from March 3, 2014 to

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April 30, 2014. It is further ordered that the scheduling conference presently set for April 22,

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2014, is continued to May ___, 2014, at 2:00 p.m.
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Dated:_____________________
March 27, 2014

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_________________________________________
UNITED STATES DISTRICT COURT JUDGE
NORTHERN DISTRICT OF CALIFORNIA

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SECOND STIPULATION TO EXTEND DEADLINE
TO RESPOND TO COM PLAINT; ORDER

Case No. 3:14-cv-00039