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Reliance Standard Life Insurance Company v. Charlie A. Harrison

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


October 28, 2011

RELIANCE STANDARD LIFE INSURANCE COMPANY
v.
CHARLIE A. HARRISON, ET AL.

The opinion of the court was delivered by: Garland E. Burrell, Jr. United States District Judge

FURTHER STIPULATION OF THE PARTIES FOR AN ORDER EXTENDING THE TIME TO FILE DISPOSITIONAL DOCUMENT AND FOR A STATUS CONFERENCE AND [PROPOSED] ORDER THEREON (L.R. 143) -- USDC EDCA Case No. CV09-00532 (KJN) Error! Unknown document property name.

The parties, Plaintiff Reliance Standard Life Insurance Company ("Reliance Standard"), 2 and Defendant Charlie Harrison ("Defendant"), by and through their attorneys of record hereby file 3 this stipulation to extend the time for the filing of a dispositional document pursuant to this Court's 4 Order dated September 13, 2011, for good cause as follows.

As stated in the prior stipulation, the key component of the settlement involves the transfer 6 of a future interest in real property. Because the real property is owned by a trust, Plaintiff is 7 working to obtain an amendment to the trust agreement as Plaintiff believes such amendment is 8 necessary. The trustee is not a party to this litigation, but has consented to the amendment. The 9 parties require additional time to secure the amendment to the trust reflecting the transfer of the future interest.

In addition, the final title report was only completed on October 25, 2011, although it was ordered by Reliance Standard several weeks ago. The parties also need additional time to resolve the few remaining differences regarding the terms of the release and settlement agreement.

Therefore, the parties respectfully request that the Court continue the date for the filing of a dispositional document from October 28, 2011, to November 23, 2011 and the status conference from November 14, 2011 to December 19, 2011 or a date that best accommodates this Court's docket so that they may secure the amendment to the trust agreement and resolve the remaining issues in the release and settlement agreement.

RESPECTFULLY SUBMITTED:

Date: October 27, 2011 WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP By: s/ Dennis J. Rhodes ADRIENNE C. PUBLICOVER DENNIS J. RHODES Attorneys for Plaintiff RELIANCE STANDARD LIFE INSURANCE COMPANY

Date: October 27, 2011 LAW OFFICES OF MICHAEL COGAN 1 2 By: s/ Michael Cogan MICHAEL COGAN GENE TUCKER Attorneys for Defendant CHARLIE HARRISON

ORDER

Pursuant to the Stipulation of the Parties herein, it is ordered that the date for filing a 8 dispositional document is continued from October 28, 2011 to November 23, 2011. A status 9 conference is set for December 12, 2011, in the event that a dispositional document is not filed by November 23, 2011. A joint status report shall be filed fourteen days prior to the hearing.

DEAC_Signature-END:

CERTIFICATE OF SERVICE

USDC EDCA

At the time of service I was over 18 years of age and not a party to this action. I am 3 employed by WILSON, ELSER, MOSKOWITZ, EDELMAN & DICKER LLP. My business address is 525 Market Street, 17th Floor, San Francisco, California 94105. My business telephone 4 number is (415) 433-0990; my business fax number is (415) 434-1370. On this date I served the following document(s):

on the person or persons listed below, through their respective attorneys of record in this action, by 8 placing true copies thereof in sealed envelopes or packages addressed as shown below by the following means of service: 9

: By United States Mail. I placed the envelope(s) for collection and mailing, following our ordinarybusiness practices. I am readily familiar with this business's practice for collecting and processing correspondence for mailing. On the same day that correspondence is placed for collection and mailing, it is deposited in the ordinary course of business with the United States Postal Service, in a sealed envelope with postage fully prepaid.

: By Overnight Delivery. I enclosed the documents in an envelope or package provided by an overnight delivery carrier and address to the persons at the addresses below. I placed the envelope or package for collection and overnight delivery at an office or a regularly utilized drop box of the overnight delivery carrier.

: By Messenger Service. I served the documents by placing them in an envelope or package addressed to the persons at the addresses listed below and provided them to a professional messenger service for service.

: By Fax Transmission. Based on an agreement of the parties to accept service by fax transmission, I faxed the documents to the persons at the fax numbers listed below. No error was reported by the fax machine that I used. A copy of the record of the fax transmission, which was printed out, is attached.

4 CERTIFICATE OF SERVICE USDC EDCA Case #CV09-00532 FCD (KJN)

: By Electronic Service. Based on a court order or an agreement of the parties to accept service by electronic transmission, I caused the documents to be sent to the persons at the electronic notification addresses listed below.

Michael Cogan, Esq. Gene Tucker, Esq. LAW OFFICES OF MICHAEL COGAN 1650 Oregon Street, Suite 106 Redding, CA 96001 Tel: (530) 246-1112 Fax: (530) 243-6079 Attorney for Defendant CHARLIE A. HARRISON

I declare under penalty of perjury under the laws of the State of California that the foregoing 8 is true and correct to the best of my knowledge. EXECUTED on October 28, 2011 at San Francisco, California.

/s/ Liza H. Cachero

Liza H. Cachero

20111028

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