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Crown Paper Liquidating Trust v. American International Group

UNITED STATES DISTRICT COURT DISTRICT OF NORTHERN CALIFORNIA


February 15, 2008

CROWN PAPER LIQUIDATING TRUST, PLAINTIFF,
v.
AMERICAN INTERNATIONAL GROUP, INC. D/B/A AIG, A DELAWARE CORPORATION; NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA., A PENNSYLVANIA CORPORATION; AIG DOMESTIC CLAIMS, INC. F/K/A AIG TECHNICAL SERVICES INC., A DELAWARE DEPT.: 17C, NINETEENTH FLOOR CORPORATION; MARSH USA RISK & INSURANCE SERVICES INC. D/B/A MARSH USA INC., A DELAWARE CORPORATION; MARSH & MCLENNAN COMPANIES, INC, A DELAWARE CORPORATION; AND DOES ONE THROUGH 50, DEFENDANTS.

ORDER APPROVING STIPULATION TO EXTEND TIME TO RESPOND TO DEFENDANTS' MOTION TO DISMISS ; CONTINUING HEARING ON DEFENDANTS' MOTIONS TO DISMISS

Judge: Maxine M. Chesney

Pursuant to Civil Local Rules 6-1, 6-2 and 7-12, the parties hereby submit a Stipulated Request for Order Changing Time.

STIPULATION TO EXTEND TIME FOR CROWN TO RESPOND TO DEFENDANTS' MOTION TO DISMISS IT IS STIPULATED BY AND BETWEEN THE PARTIES, THROUGH THEIR COUNSEL AS FOLLOWS:

Crown Paper Liquidating Trust ("Plaintiff"), Defendants Marsh USA, Inc. and Marsh & McLennan Companies ("Marsh Defendants"), and Defendants American International Group, Inc., National Union Fire Insurance Company of Pittsburgh P.A. and AIG Domestic Claims ("AIG Defendants"), (the Marsh Defendants and the AIG Defendants collectively 7 referred to as "Defendants"), through their respective counsel, stipulate and agree as follows:

1. The parties stipulate that Plaintiff shall have an extension of the time to respond to Defendants' respective Motion to Dismiss Plaintiff's First Amended Complaint which were each filed in this Court on January 28, 2008.

2. Pursuant to Local Civil Rule 6-1, the time for Plaintiff to file and serve its Response to Defendants' Motion to Dismiss is hereby extended to and including March 10, 2008. Defendants shall each have until and including March 24, 2008 to file a Reply.

3. Pursuant to Local Civil Rule 6-2, the time for Defendants to file and serve their Reply to the Plaintiff's Response is hereby extended by fourteen (14) days beyond the time set forth in Local Civil Rule 7-2(a). (See attached Declaration of Albert J. Morrison).

IT IS HEREBY STIPULATED.

DATED: February 15, 2008.

PURSUANT TO STIPULATION, IT IS SO ORDERED. Further, the hearing on defendants' motions to dismiss is continued from March 21, 2008 to April 11, 2008. DATED:

February 19, 2008

The Honorable Maxine M.Chesney I, ALBERT J. MORRISON, declare as follows:

1. I am an attorney at law duly admitted to practice before this Court. I am a member of the law firm of Beus Gilbert PLLC, counsel of record for Plaintiff Crown Paper Liquidating Trust in this matter. I have personal knowledge of the matters set forth in this declaration and if called as a witness I could and would testify competently to them.

2. Due to the unforeseen circumstances -- and unanticipated deadline - relating to another matter, the undersigned, as well as other counsel assisting the undersigned in the 8 9 instant matter, have been required to denote significant time preparing a lengthy, complex, and voluminous pleading in that matter.

3. Defendants requested, and Plaintiff agreed to, Defendants filing any Reply in Support of their respective Motions to Dismiss by March 24, 2008.

4. If the Court grants the requested time change, there would be no effect on the schedule for the case.

I declare under penalty of perjury that the foregoing is true and correct.

20080215

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