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Case 1:13-cv-00576-LJO-BAM Document 33 Filed 06/04/13 Page 1 of 3

MATTHEW A. ARIGO [SBN 254871]
BONETATI & KINCAID, INC.
2020 North Tustin Avenue
Santa Ana, California 92705
(714) 466-6600 phone
(714) 466-6601 fax

Attorneys for Defendant
UNDERWRITERS AT LLOYD'S LONDON
.





UNITED STATES DISTRICT COURT



EASTERN DISTRICT OF CALIFORNIA, FRESNO DIVISION




CASE NO.: 1:13-cv-00576-LJO-BAM




ORDER RE: STIPULATION TO EXTEND
TIME TO RESPOND TO THE
COMPLAINT

[Local Rule 144(a)]

Current Response Dates: 5/30/13 & 6/3/13

New Response Date: 6/18/13











Plaintiff,


TRAVELERS PROPERTY CASUALTY
COMPANY OF AMERICA,




vs.


OLD REPUBLIC INSURANCE COMPANY,
a Pennsylvania corporation; EVERETT
INDEMNITY INSURANCE COMPANY, a
Delaware corporation; INTERSTATE FIRE &
CASUALTY COMPANY, an Illinois
corporation; FINANCIAL PACIFIC
INSURANCE COMPANY, a California
corporation; ARCH SPECIALTY
INSURANCE COMPANY, a Nebraska
corporation; NAVIGATORS SPECIALTY
INSURANCE COMPANY, a New York
corporation; CLARENDON NATIONAL
INSURANCE COMPANY, a New Jersey
corporation; ACE AMERICAN INSURANCE
COMPANY, fka ALLIED INSURANCE
COMPANY, a Pennsylvania corporation;
NATIONAL UNION FIRE INSURANCE
COMPANY OF PITTSBURGH, PA, a North
Dakota corporation; FIRST SPECIALTY
INSURANCE CORPORATION, a Missouri
corporation; SPECIALTY INSURANCE
COMPANY, an Arizona corporation;
AMERICAN SAFETY INDEMNITY
COMPANY, an Oklahoma corporation,
LEXINGTON INSURANCE COMPANY, a
Delaware corporation; PROBUILDERS
SPECIALTY INSURANCE COMPANY,

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ORDER RE: STIPULATION TO EXTEND TIME TO RESPOND

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TO THE COMPLAINT



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Case 1:13-cv-00576-LJO-BAM Document 33 Filed 06/04/13 Page 2 of 3

RRG, a Washington, D.C. corporation;
SECURITY AMERICAN RISK RETENTION
GROUP, a Vermont corporation; ILLINOIS
UNION INSURANCE COMPANY, an
Illinois corporation; ZURICH NORTH
AMERICAN INSURANCE COMPANY, a
New York corporation; LIBERTY MUTUAL
INSURANCE COMPANY, a Massachusetts
corporation; NORTHERN INSURANCE
COMPANY OF NEW YORK, a New York
corporation; LIBERTY MUTUAL
INSURANCE COMPANY, a Massachusetts
corporation; NORTHERN INSURANCE
COMPANY OF NEW YORK, a New York
corporation; CHARTIS SPECIALTY
INSURANCE COMPANY fka AMERICAN
INTERNATIONAL SPECIALTY LINES
INSURANCE COMPANY, an Illinois
corporation; NAVIGATORS INSURANCE
COMPANY, a New York corporation;
TRUCK INSURANCE EXCHANGE, a
California corporation; CERTAIN
UNDERWRITERS AT LLOYD’S LONDON,
a Kentucky corporation; PRAETORIAN
INSURANCE COMPANY, a Pennsylvania
corporation and DOES 1 through 10, inclusive.






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Defendants.





Plaintiff Travelers Property Casualty Company of America (“Travelers”) and

Defendant UNDERWRITERS AT LLOYD'S LONDON (“Underwriters”), by and through

their counsel and pursuant to Federal Rule of Civil Procedure 6(b)(1)(A) and Local Rule

144(a), hereby stipulate to an 28-day extension of time to respond to Travelers’ Complaint in

this matter.



Travelers filed this action on April 19, 2013. Underwriters was served with the

Complaint on May 9, 2013. Pursuant to Federal Rules of Civil Procedure Rule 12(a)(1)(A)(i),

Underwriters is required to respond to the Complaint on or before May 30, 2013. Pursuant to

Eastern District Local Rule 144(a), the Parties stipulate and agree to extend these dates for 28-

days to June 28, 2013. Good cause exists for this extension to allow Underwriters time to

obtain their policies and claim files, if any, prior to responding to the Complaint. There have

ORDER RE: STIPULATION TO EXTEND TIME TO RESPOND

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TO THE COMPLAINT



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Case 1:13-cv-00576-LJO-BAM Document 33 Filed 06/04/13 Page 3 of 3

been no prior extensions of time for Underwriters to respond to the Complaint, and because

the Complaint was recently filed, there appears to be no prejudice extending the time for

Underwriters to respond to the Complaint.



WHEREFORE, for the foregoing reasons, the parties stipulate that Underwriters shall

have up to and including June 28, 2013 to answer or otherwise respond to Travelers’

Complaint.



IT IS SO STIPULATED.

Dated: May 30, 2013
































Dated: May 30, 2013













































THE AGUILERA LAW GROUP, APLC

By: /s/ Angela Martin as approved on 5/30/13






KARI M. MYRON
ANGELA MARTIN
Attorneys for Plaintiff TRAVELERS
PROPERTY CASUALTY COMPANY
OF AMERICA



BONETATI & KINCAID, INC.

By: /s/ Matthew A. Arigo as approved on 5/30/13


MATTHEW A. ARIGO
Attorneys for Defendant
UNDERWRITERS AT LLOYD'S
LONDON





IT IS SO ORDERED.


Dated: June 4, 2013






/s/ Barbara A. McAuliffe _
UNITED STATES MAGISTRATE JUDGE

ORDER RE: STIPULATION TO EXTEND TIME TO RESPOND

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TO THE COMPLAINT



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