Free Motion for Extension of Time to File Answer - District Court of California - California

Case 4:07-cv-04408-CW

Document 34

Filed 01/07/2008

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1 John H. Stephens, CSB 082971 [email protected] 2 WERTZ McDADE WALLACE MOOT & BROWER A Professional Corporation 3 945 Fourth Avenue San Diego, California 92101 4 (619) 233-1888 / Fax: (619) 696-9476 5 Attorneys for Defendant CALIFIA DEVELOPMENT CORP. dba CDC 6 INSURANCE SERVICES 7 8 9 10
WERTZ MCDADE WALLACE MOOT & BROWER

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION CASE NO. C 07-4408 (CW) STIPULATION EXTENDING THE TIME FOR DEFENDANT CALIFIA DEVELOPMENT CORP. dba CDC INSURANCE SERVICES TO RESPOND TO PLAINTIFF'S FIRST AMENDED COMPLAINT

A Professional Corporation 945 Fourth Avenue San Diego, California 92101 Tel (619) 233-1888 · Fax (619) 696-9476

11 MIDWEST TRANSPORT, INC., a Delaware Corporation, 12 Plaintiff, 13 v. 14 FCE BENEFIT ADMINISTRATORS, INC., a 15 California Corporation, 16 and 17 CALIFIA DEVELOPMENT CORP., d/b/a CDC Insurance Services, a California 18 Corporation, 19 20 21 Defendants.

Plaintiff Midwest Transport, Inc. ("Plaintiff") and Defendant Califia Development Corp.

22 dba CDC Insurance Services ("Defendant") by and through their counsel of record, enter into the 23 following Stipulation Extending the Time for Defendant to Respond to Plaintiff's First Amended 24 Complaint, with reference to the following facts: 25 /// 26 /// 27 /// 28
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Stipulation Extending Time for Defendants to Respond to Complaint Case No. C 07-4408 (CW)

Case 4:07-cv-04408-CW

Document 34

Filed 01/07/2008

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A.

Defendant's agent for service of process was served with the Plaintiff's First

2 Amended Complaint on December 18, 2007, and a response to the First Amended Complaint 3 would otherwise be due on January 7, 2008. 4 B. As a result of the intervening holidays, Defendant requires additional time to

5 review the existing documents already on file in this matter, analyze the Plaintiff's contentions and 6 formulate a response. The Plaintiff has agreed to provide Defendant with an extension of time to 7 respond to the First Amended Complaint, up to and including January 25, 2008. 8 9
WERTZ MCDADE WALLACE MOOT & BROWER

NOW, THEREFORE, the parties hereto agree as follows: 1. Defendant may have up to and including January 25, 2008, to respond to the

10 Plaintiff's First Amended Complaint. 11 2. This Stipulation may be executed in counterparts and via facsimile or other means

A Professional Corporation 945 Fourth Avenue San Diego, California 92101 Tel (619) 233-1888 · Fax (619) 696-9476

12 of electronic transmission which, when taken together, shall constitute a single, signed original. 13 14 15 Dated: December ___, 2007 16 17 18 19 20 21 22 Dated: December ___, 2007 23 24 25 26 27 28
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IT IS SO STIPULATED.

WERTZ McDADE WALLACE MOOT & BROWER A Professional Corporation

By: /s/ John H. Stephens Attorneys for Defendant CALIFIA DEVELOPMENT CORP. dba CDC INSURANCE SERVICES CARMODY MACDONALD P.C.

By: /s/ David P. Stoeberl Attorneys for Plaintiff MIDWEST TRANSPORT, INC.

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Stipulation Extending Time for Defendants to Respond to Complaint Case No. C 07-4408 (CW)