STIPULATION AND ORDER TO EXTEND DEADLINE FOR PLAINTIFF TO RESPOND TO THE COLOSI DEFENDANTS' RESPONSE TO MOTION FOR SUMMARY JUDGMENT AND COUNTERMOTION FOR (1) PARTIAL SUMMARY JUDGMENT CONCERNING DUTY TO DEFEND AND (2) TO STAY MATTER PENDING CONCLUSION OF UNDERLYING CASE [DKT 38 AND 39] AND THE COLOSI DEFENDANTS' MOTION TO STRIKE/OBJECTION TO ANY REFERENCE TO JUVENILE COURT PROCEEDINGS [DKT 40]

(FIRST REQUEST)

JENNIFER A. DORSEY, District Judge.

Pursuant to LR 6-1, Plaintiff Universal North America Insurance Company ("Universal") and Defendant Marilyn Kennedy ("Kennedy"), by and through their respective counsel of record, respectfully submit the following stipulation requesting a ten (10) day extension for Universal to file a Reply to The Colosi Defendants' Response to Motion for Summary Judgment [Dkt 38) ("Response"); The Colosi Defendants' Countermotion for (1) Partial Summary Judgment Concerning Duty to Defend and (2) to Stay Matter Pending Conclusion of Underlying Case [Dkt 39] ("Countermotion")] and The Colosi Defendants' Motion to Strike/Objection to Any Reference to Juvenile Court Proceedings [Dkt 40] ("Motion"). Universal's Motion for Summary Judgment on All Claims [dkt. 30] was filed on August 15, 2017 and the Response, Countermotion and Motion were filed on September 15, 2017. Universal's Reply to the Response [dkt 38] and Motion [dkt 40] currently due on September 29 will now be due October 9, 2017. Universal's Response to the Countermotion [dkt 39] currently due October 6, 2017 will now be due October 16, 2017. In support of this Stipulation, the parties state as follows:

A. Introduction

Universal insured Defendants Wendy, Victor and Nicholas Colosi (the "Colosi Defendants"), who are also defendants in a personal injury action filed by Kennedy. Universal filed this declaratory relief action seeking a declaration regarding its duties and obligations to the Colosi Defendants with respect to the lawsuit against them filed by Kennedy.

B. Reason for Extension

The parties believe that a ten (10) day extension of the deadline to respond to the above is necessary and appropriate to provide sufficient time for Universal to adequately respond. Universal's counsel requested the extension since she was on vacation when the Response, Motion and Countermotion were filed, which adversely interfered with Universal's opportunity to complete its Reply and Responses in a timely matter. Universal and the Colosi Defendants believe that good cause is demonstrated and both agreed to a ten (10) day extension of the deadline(s) to respond.

IT IS SO ORDERED.