Opinion
CIVIL ACTION No. 13-293
04-04-2013
FLORENCE KRUMMENACKER Plaintiff, v. H.M. INSURANCE GROUP Defendant.
JURY TRIAL DEMANDED
STIPULATION FOR EXTENSION OF TIME FOR DEFENDANT TO FILE
RESPONSIVE PLEADING TO PLAINTIFF'S COMPLAINT
AND NOW , the Parties, by and through their undersigned counsel, file this Stipulation to Extend the Deadline for the Defendant to file a responsive pleading to Plaintiff's Complaint.
WHEREAS , Plaintiff commenced this action on February 27, 2013; and
WHEREAS , Defendant requested a thirty (30) day extension to 31e a responsive pleading to the Complaint; and
WHEREAS , on March 19 2013, the parties agreed to an extension until April 29, 2013 for Defendant to file the responsive pleading; (see Exhibit 1) and
WHEREAS , the Parties seek additional time for Defendant to file a responsive pleading,
1) The Parties request that the deadline for the Defendant to file a responsive pleading be extended by a period of thirty (30) days, or until April 29, 2013; Respectfully submitted, ______________________
Timothy M. Kolman, Esquire
414 Hulmeville Ave.
Penndel, PA 19047
Attorney for Plaintiff
215-750-3134
______________________
Robert B. Cottington
PA I.D. No. 51164
rcottington@cohenlav.eom
Jessi Isenhart
PA I.D. No. 206504
jisenhart@eohenIaw.com
Cohen & Grigsby, P.C.
625 Liberty Avenue
Pittsburgh, PA 15222-3152
412-297-4900
Counsel for Defendant
______________________, C.J
Hon. Gary L. Lancaster,
Chief United States District Judge