Free Stipulation - District Court of California - California

Case 3:07-cv-04723-MHP

Document 27

Filed 02/19/2008

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FRANK S. MOORE (Bar No. CA 158029) Law Offices of Frank S. Moore, APC SUZY C. MOORE (Bar No. CA 151502) Law Offices of Suzy C. Moore 1374 Pacific Avenue San Francisco, California 94109 Telephone: (415) 292-6091 Facsimile: (415) 292-6694 Attorneys for Defendant ROSA RIVERA KEEL REED SMITH LLP HENRY C. WANG (Bar No. CA 196537) [email protected] MARK J. WAKIM (Bar No. CA 253408) [email protected] 355 South Grand Avenue, Suite 2900 Los Angeles, CA 90071 Telephone: (213) 457-8000 Facsimile: (213) 457-8080 Attorneys for Plaintiff OM FINANCIAL LIFE INSURANCE COMPANY, formerly known as Fidelity and Guaranty Life Insurance Company IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA OM FINANCIAL SERVICES COMPANY, ) ) ) Plaintiff, ) ) vs. ) ) ROSA RIVERA KEEL AND DOES 1 through ) 10, INCLUSIVE, ) ) ) Defendant. ) / No. C07-04723 MHP STIPULATION EXTENDING TIME FOR DEFENDANT ROSA RIVERA KEEL TO FILE RESPONSIVE PLEADINGS TO PLAINTIFF'S COMPLAINT Case Filed: September 13, 2007 Trial Date: TBD

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OM FINANCIAL SERVICES COMPANY v. ROSA RIVERA KEEL, et al. Case No. C07-04723 MHP

STIPULATION EXTENDING TIME FOR DEFENDANT ROSA RIVERA KEEL TO FILE RESPONSIVE PLEADINGS TO PLAINTIFF'S COMPLAINT

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Case 3:07-cv-04723-MHP

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Filed 02/19/2008

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IT IS HEREBY STIPULATED AND AGREED by and between defendant Rosa Rivera Keel by and through her counsel of record, and plaintiff OM Financial Life Insurance Company ("Plaintiff'), by and through its counsel of record, that Rosa Rivera Keel may file responsive pleadings to Plaintiff's complaint by February 29, 2008. Dated: February 14, 2008 Respectfully submitted,

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OM FINANCIAL SERVICES COMPANY v. ROSA RIVERA KEEL, et al. Case No. C07-04723 MHP

By:

/s/ signature on file Frank S. Moore Attorney for defendant Rosa Rivera Keel

Dated: February 19, 2008

Respectfully submitted,

/s/ signature on file Henry C. Wang Attorney for Plaintiff OM FINANCIAL LIFE INSURANCE COMPANY, formerly known as Fidelity and Guaranty Life Insurance Company

Filer's Attestation: Pursuant to General Order No. 45, Section X(B) regarding signatures, Frank S. Moore hereby attests that concurrence in the filing of this document has been obtained.

STIPULATION EXTENDING TIME FOR DEFENDANT ROSA RIVERA KEEL TO FILE RESPONSIVE PLEADINGS TO PLAINTIFF'S COMPLAINT

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Case 3:07-cv-04723-MHP

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Filed 02/19/2008

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PROOF OF SERVICE I, the undersigned, declare as follows: I am employed in the City and County of San Francisco, State of California. I am over the age of eighteen (18) and am not a party to this action. My business address is 1374 Pacific Avenue, San Francisco, California 94109. On the date set forth below, I served the document(s) entitled: STIPULATION EXTENDING TIME FOR DEFENDANT ROSA RIVERA KEEL TO FILE RESPONSIVE PLEADINGS TO PLAINTIFF'S COMPLAINT on the parties in this action as follows:

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OM FINANCIAL SERVICES COMPANY v. ROSA RIVERA KEEL, et al. Case No. C07-04723 MHP

REED SMITH LLP HENRY C. WANG MARK J. WAKIM 355 South Grand Avenue, Suite 2900 Los Angeles, CA 90071 X [BY MAIL] I placed the above document(s) in an envelope which was sealed, with postage thereon fully prepaid, and placed in the United States mail in San Francisco, California. I am "readily familiar" with the practice of The Law Offices of Frank S. Moore for collection and processing of correspondence for mailing, said practice being that in the ordinary course of business, mail is deposited in the United States Postal Service the same day as it is placed for collection. [VIA FACSIMILE] I transmitted the above-named documents (without attachments) at approximately __:__ _.m. on ____________, via facsimile number (415) 292-6091 to (310) 312-4224. The facsimile machine I used conveyed no error in the transmission. The transmission report was properly issued by the transmitting facsimile machine. [VIA FEDERAL EXPRESS] I am "readily familiar" with the practice of The Law Offices of William L. Osterhoudt for collection and processing of correspondence for deposit with Federal Express for overnight delivery service. Correspondence for collection and processing is either delivered to a courier or driver authorized by Federal Express to receive documents or deposited by an employee or agent of this firm in a box or facility regularly maintained by Federal Express that same day in the ordinary course of business. [VIA HAND DELIVERY BY EXPRESS COURIER] I am "readily familiar" with the practice of The Law Offices of William L. Osterhoudt for collection and processing of documents that are hand delivered via courier (Silver Bullet Delivery) and I cause the above document(s) to be delivered to Silver Bullet Delivery which in turn hand delivered the above document(s) to counsel at the address listed above on this date. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. DATED: February 19, 2008 /s/ signature on file Frank S. Moore

STIPULATION EXTENDING TIME FOR DEFENDANT ROSA RIVERA KEEL TO FILE RESPONSIVE PLEADINGS TO PLAINTIFF'S COMPLAINT

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