STIPULATION EXTENDING TIME FOR THIRD PARTY DEFENDANT EXECUTIVE RISK INDEMNITY, INC. TO FILE INITIAL RESPONSE TO NATIONAL UNION'S THIRD PARTY COMPLAINT

[Local Rule 6-1(a)]

EDWARD J. DAVILA, District Judge.

Pursuant to Local Rule 6-1(a), Third Party Plaintiff National Union Fire Insurance Company of Pittsburgh, P.A. ("National Union") and Third Party Defendant Executive Risk Indemnity, Inc. ("ERII") (collectively with National Union, the "Parties"), by and through their respective counsel, hereby stipulate and agree to extend the time for ERII to answer or otherwise respond to National Union's Amended Third-Party Complaint (Dkt. 264) as follows:

On August 4, 2014, National Union filed its original Third Party Complaint naming ERII;

On August 18, 2014, National Union filed its operative Amended Third Party Complaint against ERII, and subsequently served ERII, making ERII's initial response due on September 2, 2014;

ERII's counsel has requested, and National Union's counsel has agreed to a fourteen (14) day extension of time for ERII to file its initial response to National Union's operative Third Party Complaint, making ERII's response due on September 16, 2014;

The Parties believe that extending the newly added ERII's deadline to file its initial response will not alter the date of any event or any deadline already fixed by Court order or otherwise have a negative effect on the future scheduling in this action;

THEREFORE, IT IS HEREBY STIPULATED by and between the Parties' undersigned counsel that ERII shall file its initial response to National Union's operative Third Party Complaint on or before September 16, 2014.