Opinion
Case No. 2:12-cv-03041-LKK-GGH
02-28-2013
ST. PAUL FIRE AND MARINE INSURANCE COMPANY, a Minnesota corporation; ST. PAUL MERCURY INSURANCE COMPANY, a Minnesota corporation, Plaintiff, v. ACE AMERICAN INSURANCE, et al., Defendants.
ANDREW D. HEROLD, ESQ., Bar No. 178640 KENDALL DULICH, ESQ., Bar No. 178307 HEROLD & SAGER Attorneys for Defendants CHARTIS SPECIALTY INSURANCE COMPANY fka AMERICAN INTERNATIONAL SPECIALTY LINES INSURANCE COMPANY, NATIONAL UNION FIRE INSURANCE COMPANY, and LEXINGTON INSURANCE COMPANY
ANDREW D. HEROLD, ESQ., Bar No. 178640
KENDALL DULICH, ESQ., Bar No. 178307
HEROLD & SAGER
Attorneys for Defendants
CHARTIS SPECIALTY INSURANCE COMPANY fka AMERICAN INTERNATIONAL
SPECIALTY LINES INSURANCE COMPANY, NATIONAL UNION FIRE INSURANCE
COMPANY, and LEXINGTON INSURANCE COMPANY
STIPULATION AND ORDER TO EXTEND
TIME TO FILE A RESPONSIVE
PLEADING
This Stipulation is entered into by and between Plaintiffs ST. PAUL FIRE AND MARINE INSURANCE COMPANY AND ST. PAUL MERCURY INSURANCE COMPANY (collectively "St. Paul") and Defendants CHARTIS SPECIALTY INSURANCE COMPANY fka AMERICAN INTERNATIONAL SPECIALTY LINES INSURANCE COMPANY ("Chartis Specialty"), NATIONAL UNION FIRE INSURANCE COMPANY ("National Union") and LEXINGTON INSURANCE COMPANY ("Lexington"), (collectively "Defendants") by and through their respective attorneys' of record.
RECITALS
1. WHEREAS St. Paul filed its complaint in the instant action on December 18, 2012;
2. WHEREAS St. Paul served Defendants on January 18, 2013 with the summons and complaint in this action;
3. WHEREAS St. Paul and Chartis Specialty initially agreed to extend the deadline for Chartis Specialty to respond to the complaint to March 1, 2013;
4. WHEREAS St. Paul and Chartis Specialty have agreed to a second extension of nineteen (19) days for Chartis to respond to the complaint;
5. WHEREAS St. Paul and National Union have agreed to an extension for National Union to respond to the complaint;
6. WHEREAS St. Paul and Lexington have agreed to an extension for Lexington to respond to the complaint
IT IS HEREBY STIPULATED AND AGREED:
7. Subject to the Court's approval, Defendants shall file a responsive pleading to the complaint on or before March 20, 2013.
8. This stipulation shall not constitute an appearance by Defendants. Defendants do not waive their right to challenge the Court's jurisdiction over this matter and/or whether Defendants were validly served with summons and complaint.
HEROLD & SAGER
Kendall Dulich
ANDREW D. HEROLD, ESQ.
KENDALL DULICH, ESQ.
Attorneys for Defendant
Chartis Specialty Insurance Company, National
Union Fire Insurance Company and Lexington
Insurance Company
THE AGUILERA LAW GROUP, APLC
Angela Martin (as authorized 2.27.13)
A. ERIC AGUILERA
DANIEL ELI
ANGELA MARTIN
Attorneys for Plaintiff
ST. PAUL FIRE AND MARINE INSURANCE
COMPANY and ST. PAUL MERCURY
INSURANCE COMPANY
ORDER
The Court having reviewed the stipulation between Plaintiffs ST. PAUL FIRE AND MARINE INSURANCE COMPANY and ST. PAUL MERCURY INSURANCE COMPANY, and Defendants CHARTIS SPECIALTY INSURANCE COMPANY fka AMERICAN INTERNATIONAL SPECIALTY LINES INSURANCE COMPANY ("Chartis Specialty"), NATIONAL UNION FIRE INSURANCE COMPANY ("National Union") and LEXINGTON INSURANCE COMPANY ("Lexington"), (collectively "Defendants") extending the time for Defendants to respond to the complaint, the Court grants the stipulation and orders that Defendants shall have through and until March 20, 2013 to respond to the Complaint.
IT IS SO ORDERED.
______________________
LAWRENCE K. KARLTON
SENIOR JUDGE
UNITED STATES DISTRICT COURT