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National Union Fire Insurance Company of Pittsburgh, Pa v. Payless Shoe Source

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION


July 13, 2011

NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA., PLAINTIFF,
v.
PAYLESS SHOE SOURCE, INC. AND COLLECTIVE BRANDS, INC., DEFENDANTS.

The opinion of the court was delivered by: Edward M. Chen U.S. District Judge

SEDGWICK LLP BRUCE D. CELEBREZZE Bar No. 102181 bruce.celebrezze@sedgwicklaw.com NICHOLAS J. BOOS Bar No. 233399 nicholas.boos@sedgwicklaw.com One Market Plaza Steuart Tower, 8th Floor San Francisco, California 94105 Telephone: (415) 781-7900 Facsimile: (415) 781-2635 Attorneys for Plaintiff NATIONAL UNION FIRE INSURANCE COMPANY OF PITTSBURGH, PA.

STIPULATION FOR FURTHER EXTENSION OF TIME TO RESPOND TO COMPLAINT ; ORDER

Pursuant to Civil Local Rule 6-1(a) for the Northern District of California, Plaintiff National Union Fire Insurance Company of Pittsburgh, PA and Defendants, Payless Shoe Source, Inc. and Collective Brands, Inc. (collectively, with Plaintiff, the "Parties"), by their 24 undersigned attorneys, stipulate to a further extension of time for Defendants to answer, move, or 25 otherwise respond to the Complaint in this matter, without waiver of any rights, claims or 26 defenses, including the right to seek further extensions.

Respond to Complaint, extending Defendants' time to respond to the Complaint through July 19,

On May 26, 2011, the Parties submitted to the Court a Stipulation to Extend Time to

2011. (ECF No. 8.) Pursuant to Civil Local Rule 6-1(a), the parties by and through their 4 counsel, stipulate to a further extension of time, as follows:

for Declaratory Relief on or before August 18, 2011 (the "Response Date");

2. This extension does not alter the date of any event or any deadline already fixed by Court order, as all such deadlines were vacated pursuant to the Court's Reassignment Order (ECF No. 13);

3. Defendants agree not to commence any action, or maintain any proceedings, against Plaintiff in any other jurisdiction in connection with the claims in this action at any time prior to the Response Date; provided, however, that this stipulation does not limit in any way Defendants' right or ability to commence an action or maintain proceedings, against Plaintiff in connection with the claims in this action on or after the Response Date;

4. By entering into this Stipulation, the Parties do not waive, and expressly preserve, any and all rights, claims and defenses, including all defenses relating to jurisdiction, venue and arbitrability.

1. Defendants shall answer, move, or otherwise respond to Plaintiff's Complaint Respectfully submitted,

IT IS SO ORDERED:

IT IS SO ORDERED.

I, Nicholas J. Boos, am the ECF User whose ID and password are being used to file this Stipulation To Extend Time To Respond To The Complaint. In compliance with General Order 45, X.B., I hereby attest that Robert A. Sacks and Sverker K. H gberg have concurred in this filing.

Nicholas J. Boos

20110713

© 1992-2011 VersusLaw Inc.



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