AIG Specialty Insurance Company v. Liberty Mutual Insurance Company

Filing 56

ORDER Granting 55 Stipulation for Extension of Time re 51 Motion to Stay (First Request). Responses due by 8/30/2017. Signed by Magistrate Judge Nancy J. Koppe on 8/16/17. (Copies have been distributed pursuant to the NEF - MR)

Case 2:17-cv-01260-APG-NJK Document 55 Filed 08/15/17 Page 1 of 3

1 ANDREW D. HEROLD, ESQ.
Nevada Bar No. 7378
2 JOSHUA A. ZLOTLOW, ESQ.
Nevada Bar No. 11333
3
HEROLD & SAGER
4 3960 Howard Hughes Parkway, Suite 500
Las Vegas, NV 89169
5 Telephone: [phone]
Facsimile: [phone]
6 [e-mail]
[e-mail]
7
8 Attorneys for Plaintiff AIG SPECIALTY INSURANCE COMPANY F/K/A CHARTIS
SPECIALTY INSURANCE COMPANY AND ALSO AMERICAN INTERNATIONAL
9 SPECIALTY LINES INSURANCE COMPANY
10
11

UNITED STATES DISTRICT COURT

12

DISTRICT OF NEVADA

13 AIG SPECIALTY INSURANCE COMPANY
F/K/A CHARTIS SPECIALTY INSURANCE
14 COMPANY AND ALSO AMERICAN
15 INTERNATIONAL SPECIALTY LINES
INSURANCE COMPANY, an Illinois
16 Corporation,
17

Plaintiff,

18

vs.

19
20 LIBERTY MUTUAL FIRE INSURANCE
COMPANY, a Massachusetts Corporation,
21
Defendant.
22

CASE NO. 2:17-cv-01260-APG-NJK
STIPULATION AND ORDER
EXTENDING TIME FOR AIG
SPECIALTY INSURANCE COMPANY
F/K/A CHARTIS SPECIALTY
INSURANCE COMPANY AND ALSO
AMERICAN INTERNATIONAL
SPECIALTY LINES INSURANCE
COMPANY’S TO FILE OPPOSITION TO
LIBERTY MUTUAL’S RENEWED
MOTION TO STAY FEDERAL COURT
DECLARATORY JUDGMENT ACTION
PENDING RESOLUTION OF
UNDERLYING COURT ACTION
(FIRST REQUEST)

23
Plaintiff AIG SPECIALTY INSURANCE COMPANY F/K/A CHARTIS SPECIALTY

24

25 INSURANCE COMPANY AND ALSO AMERICAN INTERNATIONAL SPECIALTY LINES
26 INSURANCE COMPANY (“AISLIC”) and Defendant, LIBERTY MUTUAL FIRE INSURANCE
27 COMPANY (“Liberty” and collectively, with AISLIC the “Parties”), by and through their
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STIPULATION EXTENDING TIME TO FILE OPPOSITION TO
LIBERTY MUTUAL’S RENEWED MOTION TO STAY

CASE NO. 2:17-cv-01260-APG-NJK

Case 2:17-cv-01260-APG-NJK Document 55 Filed 08/15/17 Page 2 of 3

1 attorneys of record, and pursuant to Local Rules 6-1(a)(b)(c) and 6-2, hereby stipulate and agree as
2 follows:
3

WHEREAS, Defendant filed its Renewed Motion to Stay (ECF No. 51) on August 9, 2017;

4

WHEREAS, Plaintiff has requested, and Defendant has consented to, an extension of time

5 to respond to Defendant’s Renewed Motion to Stay to August 30, 2017;
WHEREAS, Plaintiff’s handling attorneys are either out of the country or are otherwise

6

7 unavailable during the time frame before the opposition’s current due date;
WHEREAS, Fed.R.Civ.P. 6(b) requires the Court to approve an extension of time for

8

9 Plaintiff to file a response, and therefore the Parties collectively request the Court approve the
10 stipulation, as set forth below:
a.

11

This is the Parties’ first stipulation for enlargement of time to answer Defendant’s
Renewed Motion to Stay;

12
b.

13

The Parties stipulate and agree that the deadline for Plaintiff to file a response to
Defendant’s Renewed Motion to Stay shall be extended to August 30, 2017.

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STIPULATION EXTENDING TIME TO FILE OPPOSITION TO
LIBERTY MUTUAL’S RENEWED MOTION TO STAY

CASE NO. 2:17-cv-01260-APG-NJK

Case 2:17-cv-01260-APG-NJK Document 55 Filed 08/15/17 Page 3 of 3

1

c.

This stipulation is not made for purposes of delay.

2
3 DATED: August 15, 2017

HEROLD & SAGER

4
5

By: /s/ Andrew D. Herold
ANDREW D. HEROLD, ESQ.
Nevada Bar No. 7378
JOSHUA A. ZLOTLOW, ESQ.
Nevada Bar No. 11333
Attorneys for Plaintiff AIG SPECIALTY
INSURANCE COMPANY F/K/A CHARTIS
SPECIALTY INSURANCE COMPANY AND
ALSO AMERICAN INTERNATIONAL
SPECIALTY LINES INSURANCE COMPANY

6
7
8
9
10
11
12 DATED: August 15, 2017

DUANE MORRIS, LLP

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14

By: /s/ Dominica C. Anderson
DOMINICA C. ANDERSON, ESQ. SBN 2988
DANIEL B. HEIDTKE, ESQ. SBN 12975
Attorneys for Defendant LIBERTY MUTUAL
FIRE INSURANCE COMPANY

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20
August 16
21 IT IS SO ORDERED this

day of

, 2017.

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25

U.S. DISTRICT MAGISTRATE JUDGE

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STIPULATION EXTENDING TIME TO FILE OPPOSITION TO
LIBERTY MUTUAL’S RENEWED MOTION TO STAY

CASE NO. 2:17-cv-01260-APG-NJK