Opinion
Case No.: 2:11-cv-00881-KJM-DAD
08-29-2011
Richard S. Endres London Fischer LLP Attorneys for Defendant ACE AMERICAN INSURANCE COMPANY Jonathan Gross Vivian Leung Lerche Attorneys for Plaintiff ZURICH AMERICAN INSURANCE COMPANY
Jonathan Gross, State Bar No. 122010
jgross@bishop-barry.com
Vivian L. Lerche, State Bar No. 149984
vlerche@bishop-barry.com
BISHOP | BARRY | DRATH
2000 Powell Street, Suite 1425
Emeryville, California 94608
Telephone: (510) 596-0888
Facsimile: (510) 596-0889
Attorneys for Plaintiff
ZURICH AMERICAN INSURANCE COMPANY
JOINT STIPULATION AND ORDER TO
EXTEND TIME TO ANSWER INITIAL
COMPLAINT (L.R. 144)
Pursuant to Rule 144, subdivision (a), of the Local Rules of the United States District Court for the Eastern District of California, Plaintiff ZURICH AMERICAN INSURANCE COMPANY ("Plaintiff"), through its counsel, and Defendant ACE AMERICAN INSURANCE COMPANY ("Defendant"), through its counsel, hereby stipulate and agree:
Defendant shall have an extension of time to Answer the Complaint, from August 12, 2011 up to and including September 23, 2011.
Good cause for this extension is based on the following:
1. The parties hereto sought to resolve this matter prior to the filing of the litigation.
2. Plaintiff was required to file the instant action on April 1, 2011 in order to preserve the statute of limitations.
3. The Summons and Complaint were served on Defendant on July 22, 2011
4. Additional time is needed for the parties to engage in settlement negotiations to determine if the dispute may be resolved without resort to the pending litigation.
5. It is in the interest of judicial economy that this Joint Stipulation be approved and the Order be signed and issued by the Court.
By: Richard S. Endres
London Fischer LLP
Attorneys for Defendant
ACE AMERICAN INSURANCE
COMPANY
BISHOP | BARRY | DRATH
By: Jonathan Gross
Vivian Leung Lerche
Attorneys for Plaintiff
ZURICH AMERICAN INSURANCE
COMPANY
ORDER
PURSUANT TO THE PARTIES' STIPULATION, the Court finds good cause to extend the time for ACE AMERICAN INSURANCE COMPANY'S time to Answer the initial Complaint filed by ZURICH AMERICAN INSURANCE COMPANY to September 23, 2011. The status (pretrial scheduling) conference set for September 7, 2011 is VACATED and RESET to October 5, 2011.
IT IS SO ORDERED.
____________
UNITED STATES DISTRICT JUDGE