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Davis v. Riversource Life Insurance Co.

United States District Court, N.D. California

July 11, 2016

PAUL M. DAVIS, individually and as trustee/settlor/grantor of the PAUL M. DAVIS REVOCABLE TRUST OF 2011, and the PAUL M. DAVIS REVOCABLE TRUST OF 2011, Plaintiffs,
v.
RIVERSOURCE LIFE INSURANCE COMPANY, a Minnesota corporation, AMERIPRISE FINANCIAL SERVICES, INC., a Delaware corporation, AMERIPRISE HOLDINGS, INC., a Delaware corporation, and AMERIPRISE FINANCIAL, INC., a Delaware corporation, Defendants.

          Paul M Davis, Plaintiff, represented by Michael Aaron Levy, Evans Law Firm, Inc., Andrew S. Friedman, Bonnett Fairbourn Friedman & Balint, P.C, pro hac vice, Francis Joseph Balint, Jr., Bonnett Fairbourn Friedman & Balint, PC, pro hac vice & Ingrid M. Evans, Evans Law Firm, Inc..

          Paul M. Davis Revocable Trust of 2011, Plaintiff, represented by Michael Aaron Levy, Evans Law Firm, Inc., Andrew S. Friedman, Bonnett Fairbourn Friedman & Balint, P.C, pro hac vice, Francis Joseph Balint, Jr., Bonnett Fairbourn Friedman & Balint, PC, pro hac vice & Ingrid M. Evans, Evans Law Firm, Inc..

          RiverSource Life Insurance Company, Defendant, represented by Linda Beth Oliver, Maynard Cooper & Gale, LLP.

          Ameriprise Financial, Inc., Defendant, represented by Linda Beth Oliver, Maynard Cooper & Gale, LLP.

          Ameriprise Financial Services, Inc., Defendant, represented by Linda Beth Oliver, Maynard Cooper & Gale, LLP.

          Ameriprise Holdings, Inc., Defendant, represented by Linda Beth Oliver, Maynard Cooper & Gale, LLP.

          JOINT STIPULATION TO CONTINUE DEADLINE FOR DEFENDANTS TO RESPOND TO PLAINTIFFS' COMPLAINT

          JOSEPH C. SPERO, District Judge.

         JOINT STIPULATION

         Pursuant to Civil Local Rule 6-1, Plaintiff Paul M. Davis, individually and as trustee/settlor/grantor of the Paul M. Davis Revocable Trust of 2011 and Plaintiff the Paul M. Davis Revocable Trust of 2011 ("Plaintiffs") and Defendants RiverSource Life Insurance Company ("RiverSource"), Ameriprise Financial Services, Inc., Ameriprise Holdings, Inc. and Ameriprise Financial, Inc. (collectively, the "Parties"), make a special and limited appearance to hereby jointly stipulate to an extension of time for Defendants to respond to Plaintiffs' Complaint. The Parties agree and stipulate that Defendants will respond to Plaintiff's Complaint on or before July 21, 2016. In support of this Stipulation, the Parties agree and stipulate as follows:

         1. On May 24, 2016, Plaintiffs initiated the present action against Defendants in the United States District Court for the Northern District of California. ( See ECF Doc. No. 1).

         2. Defendants were served with the Summons and Complaint in this action on May 31, 2016. Defendants' responsive pleading is therefore due on or before June 21, 2016.

          3. The Parties have agreed to a thirty (30) day extension of time for Defendants to respond to Plaintiffs' Complaint from the original date.

         4. This Stipulation is necessary because Defendants' counsel need additional time to review and research the issues raised by Plaintiffs' Complaint and to frame appropriate responsive pleadings or motions. Nothing herein shall be construed as a waiver of any defense by any Defendant including, but not limited to, those defenses specifically identified in Rules 8 and 12 of the Federal Rules of Civil Procedure.

         5. This Stipulation will not alter the date of any event or deadline ...


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