Opinion
2:22-cv-1904-APG-NJK
10-13-2023
PATRICIA SOMERS, as alleged trustee for the Valesco Irrevocable Trust dated June 16, 2004, Plaintiff, v. MIDLAND NATIONAL LIFE INSURANCE COMPANY, efendant.
HOLLEY DRIGGS GODFREY & KAHN, SC PAUL F. HEATON, ESQ., HUNTER M. VAN ASTEN, ESQ., HOLLEY DRIGGS F. THOMAS EDWARDS, ESQ. JESSICA M. LUJAN, ESQ. Attorneys for Defendant, Midland National Life Insurance Company LEE KIEFER & PARK, LLP MATTHEW W. PARK, ESQ. T. CHASE PITTSENBARGER Attorneys for Plaintiff, Patricia Somers, Trustee
HOLLEY DRIGGS
GODFREY & KAHN, SC
PAUL F. HEATON, ESQ.,
HUNTER M. VAN ASTEN, ESQ.,
HOLLEY DRIGGS
F. THOMAS EDWARDS, ESQ.
JESSICA M. LUJAN, ESQ.
Attorneys for Defendant, Midland National Life Insurance Company
LEE KIEFER & PARK, LLP
MATTHEW W. PARK, ESQ.
T. CHASE PITTSENBARGER
Attorneys for Plaintiff, Patricia Somers, Trustee
ORDER TO EXTEND DEADLINE TO RESPOND TO PLAINTIFF'S MOTION FOR LEAVE TO AMEND HER PETITION (ECF NO. 36)
(FIRST REQUEST)
NANCY J. KOPPE, UNITED STATES MAGISTRATE JUDGE.
Midland National Life Insurance Company, the defendant in this action (“Midland”), by and through its counsel of record, the law firm of Holley Driggs, and the Plaintiff, by and through her counsel of record, the law firm of Lee Kiefer & Park, LLP, hereby stipulate and agree as follows:
1. On October 9, 2023, Plaintiff filed her Motion for Leave to Amend her Petition (ECF No. 36).
2. The current deadline for Midland to respond to the Motion for Remand is October
23, 2023 (the “Response Deadline”).
3. The parties have agreed that a two-week extension of the Response Deadline is appropriate given conflicting commitments of Midland's counsel prior to the Response Deadline, including, without limitation, the preparation of summary judgment motions in two matters being handled by lead counsel for Midland, and the conducting of expedited discovery in anticipation of a potential amendment of pleadings in another federal court action. These commitments, coupled with the other ongoing obligations of counsel, render an extension of time appropriate.
4. Accordingly, the parties stipulate and agree that the Response Deadline shall be extended to November 6, 2023. This is the parties' first request for an extension of this deadline, and such request is not meant for the purpose of causing undue delay.
IT IS SO STIPULATED.
ORDER
IT IS SO ORDERED.