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American Steel & Stairways, Inc v. Lexington Insurance Company

November 21, 2012

AMERICAN STEEL & STAIRWAYS, INC.;
MARTIN VOLLRATH, AN INDIVIDUAL; AND
THOMAS VOLLRATH, AN INDIVIDUAL,
PLAINTIFFS,
v.
LEXINGTON INSURANCE COMPANY, A INITIAL CASE MANAGEMENT DELAWARE CORPORATION;
INSURANCE COMPANY OF THE STATE OF PENNSYLVANIA, A PENNSYLVANIA CORPORATION; AND DOES 1 THROUGH 100, INCLUSIVE, DEFENDANTS.



The opinion of the court was delivered by: Honorable Susan Illston United States District Court Judge

[The Honorable Susan Illston]

STIPULATION AND [PROPOSED] ORDER TO EXTEND MEDIATION DEADLINE; CONTINUE DATE OF CONFERENCE AND WITHDRAW MOTION TO EXTEND DEADLINE FOR COMPLETING MEDIATION

Northern District of California, Defendants Lexington Insurance Company ("Lexington") and 3 the Insurance Company of the State of Pennsylvania, ("ISOP") and Plaintiffs American Steel & 4 "Parties," by their undersigned attorneys, hereby stipulate and agree as follows: 6 16, 2012 and the case was removed to Federal Court on June 15, 2012; 8 2012 at 2:30 p.m. and then reset the date for September 20, 2012 at 2:30 p.m.; 10 4, 2012 directing a presumptive deadline of December 3, 2012; 12 13 the initial case management conference for November 30, 2012; 14 15 appointing Anne Lawlor Goyette as mediator; 16 17 appointed mediator on November 5, 2012; 18

WHEREAS, the mediator has agreed to schedule a mediation of this matter for January 10, 2013 if the Court grants an extension of the mediation deadline; 21 November 19, 2012 [Dkt. #58]; 23

Completing Mediation is moot and Plaintiffs agree to withdraw the motion; 25 Parties' mediation to avoid unnecessary expenditure of the Court and Parties' time and 27 resources; 28 Pursuant to Civil Local Rules, 16-2(e), 7-12, 6-1 and 6-2 and ADR Local Rule 6-5 for the Stairways, Inc., Martin Vollrath and Thomas Vollrath (collectively "Plaintiffs"), collectively the 5

WHEREAS, Plaintiffs filed a Complaint in San Mateo County Superior Court on April

WHEREAS, the Court set the initial case management conference for September 21,

WHEREAS, the Court ordered this matter to mediation under ADR L.R. 6 on September

WHEREAS, on September 10, 2012, the Court, on its own motion, continued the date of

WHEREAS, the Court issued its notice of appointment of mediator on October 3, 2012,

WHEREAS, counsel for the Parties conducted their initial telephone conference with the

WHEREAS, Plaintiffs need additional time to prepare for the mediation;

WHEREAS, Plaintiffs filed a Motion to Extend Deadline for Completing Mediation on

WHEREAS, pursuant to this Stipulation, Plaintiffs' Motion to ...


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