Filed: Jan. 14, 2013
Latest Update: Jan. 14, 2013
Summary: STIPULATION EXTENDING TIME FOR DEFENDANT TO RESPOND TO COMPLAINT AND CONTINUING INITIAL CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER MARIA-ELENA JAMES, Magistrate Judge. Pursuant to Northern District Civil Local Rules 6-1(a), 7-12, and 16-2(d), Plaintiff State Farm Mutual Automobile Insurance Company and Defendant United States of America hereby submit the following stipulation and proposed order extending the time for Defendant to respond to the Complaint and continuing the Initial Case Ma
Summary: STIPULATION EXTENDING TIME FOR DEFENDANT TO RESPOND TO COMPLAINT AND CONTINUING INITIAL CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER MARIA-ELENA JAMES, Magistrate Judge. Pursuant to Northern District Civil Local Rules 6-1(a), 7-12, and 16-2(d), Plaintiff State Farm Mutual Automobile Insurance Company and Defendant United States of America hereby submit the following stipulation and proposed order extending the time for Defendant to respond to the Complaint and continuing the Initial Case Man..
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STIPULATION EXTENDING TIME FOR DEFENDANT TO RESPOND TO COMPLAINT AND CONTINUING INITIAL CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER
MARIA-ELENA JAMES, Magistrate Judge.
Pursuant to Northern District Civil Local Rules 6-1(a), 7-12, and 16-2(d), Plaintiff State Farm Mutual Automobile Insurance Company and Defendant United States of America hereby submit the following stipulation and proposed order extending the time for Defendant to respond to the Complaint and continuing the Initial Case Management Conference in this action.
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WHEREAS, on September 7, 2012, Plaintiff filed this subrogation action seeking $5,000.98 in damages in connection with an insurance claim that was paid by Plaintiff to a policyholder involved in a motor vehicle accident with an individual allegedly acting at the time within the course and scope of his employment by the United States Mint;
WHEREAS, on January 11, 2013, the parties filed a Stipulation for Compromise Settlement and Release ("Settlement Agreement"), which would resolve all claims asserted in this action, see Dkt. No. 7;
WHEREAS, the Settlement Agreement contemplates the entry of a Stipulation of Dismissal with Prejudice upon payment by Defendant of the Settlement Amount described therein, see id. ¶¶ 3, 5 & Ex. A;
NOW, THEREFORE, to provide the parties with additional time to fulfill the obligations undertaken by them under the Settlement Agreement, such that the above-referenced stipulation of dismissal may be entered without need for further proceedings before this Court, it is hereby agreed by Plaintiff and Defendant that:
(1) Defendant's deadline to respond to the Complaint in this action shall be extended by one-hundred-and-twenty (120) days, until and including Tuesday, May 14, 2013; and
(2) the Initial Case Management Conference set in this action shall be continued until May 30, 2013, at 10:00 a.m. and all other deadlines set by the Court in its Order Setting Initial Case Management Conference shall be continued by the same interval, such that the parties' Management Statement(s) shall be due on or before May 23, 2013, and the meet-and-confer deadlines set in the Court's order shall be May 9, 2013.
IT IS SO STIPULATED.
DATED: January 11, 2013 Respectfully submitted,
MELINDA HAAG
United States Attorney
/s/Mark R. Conrad
Assistant United States Attorney
Attorneys for Defendant
DATED: January 11, 2013.
REESE LAW GROUP
Joseph M. Pleasant
/s/Joseph M. Pleasant
Attorneys for Plaintiff
[PROPOSED] ORDER
Pursuant to the stipulation of the parties, the Court hereby ORDERS that the deadline for Defendant to respond to the Complaint in this action shall be extended until and including May 14, 2013; and further ORDERS that the Initial Case Management Conference in this matter set for February 7, 2013, is hereby VACATED and CONTINUED until May 30, 2013, at 10:00 a.m. The parties shall file a Joint Case Management Statement not later than May 23, 2013.
PURSUANT TO STIPULATION, IT IS SO ORDERED.
