STIPULATION EXTENDING THE TIME TO HEAR DISPOSITIVE MOTIONS AND ORDER

CHARLES R. BREYER, District Judge.

It is hereby stipulated by and between plaintiff CONTINENTAL CASUALTY COMPANY("Continental Casualty") and defendant GOLDEN EAGLE INSURANCE CORPORATION ("Golden Eagle"), by and through their attorneys of record, that the parties shall petition this Court to extend the deadline to hear dispositive motions in this action from December 12, 2014 to June 11, 2015. Good cause exists to grant this request as this case involves Continental Casualty's complaint for contribution to the defense of its insured. At the time of the case management conference, the parties believed the legal questions in this case to be simple, with minimal discovery required. However, discovery has recently revealed several other entities that may have insurance that potentially would be obligated to provide a defense to its insured.

On September 12, 2014, the parties discussed new information from the Marin County Assessor's office showing that the property at issue in the underlying action to this case was not owned solely by Golden Eagle's insured, as alleged by Continental Casualty, but is in fact owned jointly by three family trusts. The parties agreed that this information is relevant and that further discovery needs to be conducted to review any applicable insurance policies held by these entities or their trustees that could impact Continental Casualty's claim.

The parties hope to amicably settle this case once the parties obtain through discovery a better picture of the insurance coverage issues in this case.

Extension of this deadline will affect no other deadlines in this action.

The Court has currently set a December 12, 2014 deadline for hearing of dispositive motions in this case. To meet that deadline, the parties must file their motions for summary judgment no later than November 7, 2014. The parties do not believe they will be able to identify all insurers with potential coverage obligations in this case, determine whether each insurer is in fact obligated to provide a defense, and reach a settlement of the case prior to November 7, 2014.

The parties therefore stipulate and agree to ask this Court to extend the deadline to hear dispositive motions in this case to June 11, 2015, to allow the parties to more fully investigate the other potential parties to Continental Casualty's lawsuit and to allow those parties the opportunity to attempt to settle this action.

IT IS SO STIPULATED.

[PROPOSED] ORDER

Good cause appearing, this Court hereby grants the parties request to extend the deadline to hear dispositive motions in this action. The parties shall have until June 11, 2015 for dispositive motions to be heard.

IT IS SO ORDERED.