Opinion
CASE NO.: 4:11-cv-00546-CW
11-15-2011
AVEMCO INSURANCE COMPANY, Plaintiff, v. ROBERT S. SAVELY, PATRIOT TECHNOLOGIES GROUP, LLC, a Delaware limited liability corporation, Defendants.
REID, AXELROD By: Donald S. Honigman, SB# 106914 Peter Axelrod, SB# 056485 REID, AXELROD Attorneys for Plaintiff AVEMCO INSURANCE COMPANY THE RYAN LAW GROUP By: Timothy J. Ryan, SB# 99542 Rebekka R. Martorano, SB# 173600 THE RYAN LAW GROUP Attorneys for Defendant ROBERT S. SAVELY
REID, AXELROD,
Peter Axelrod SB#056485
Donald S. Honigman SB# 106914
Attorneys for Plaintiff
AVEMCO INSURANCE COMPANY
STIPULATION AND [PROPOSED] ORDER REGARDING DEADLINE FOR FACTUAL DISCOVERY
IT IS HEREBY STIPULATED by and between Plaintiff AVEMCO INSURANCE COMPANY (hereinafter "Plaintiff" or "AVEMCO") and Defendant ROBERT S. SAVELY (hereinafter "SAVELY") (collectively the "Parties") by and through their respective attorneys, as follows:
1. On February 4, 2011 Plaintiff filed a Complaint for Declaratory Relief in United States District Court-Northern District of California, Case Number CV 11 0546 CW (hereinafter the "Complaint") against PATRIOT TECHNOLOGIES GROUP, LLC (hereinafter "PATRIOT") and SAVELY. The Complaint asked that the Court to determine the respective rights and duties of Plaintiff and Defendants as to AVEMCO policy NC-100118290600.
2. On April 13, 2011 Defendant PATRIOT signed a Stipulation Regarding Declaratory Action, wherein it stipulated to the allegations in Plaintiff's Complaint and stipulated that it had no rights under the Avemco policy. On April 15, 2011, Plaintiff filed a Notice of Dismissal of PATRIOT, only.
3. On May 31, 2011, the Parties attended a Case Management Conference. The Court issued its Minute Order and Case Management Order.
4. The Court ordered completion of factual discovery by December 1 ,2011.
5. The Parties are presently engaged in discovery and require additional time to complete factual discovery.
6. Based on the above, the Parties respectfully request that the Court continue the deadline for completion of factual discovery (currently December 1,2011) by at least 90 days.
IT IS SO STIPULATED:
REID, AXELROD
By: Donald S. Honigman, SB# 106914
Peter Axelrod, SB# 056485
REID, AXELROD
Attorneys for Plaintiff
AVEMCO INSURANCE COMPANY
THE RYAN LAW GROUP
By: Timothy J. Ryan, SB# 99542
Rebekka R. Martorano, SB# 173600
THE RYAN LAW GROUP
Attorneys for Defendant
ROBERT S. SAVELY
ORDER
IT IS HEREBY ORDERED that the deadline for completion of factual discovery in the above referenced case is continued 90 days to February 29, 2012.
IT IS SO ORDERED.
CLAUDIA WILKEN
United States District Judge