Arizona Civil Constructors, Inc. v. Colony Insurance Company

ROBERT E. SCHUMACHER, ESQ.

2 Nevada Bar No. 7504 DIONE C. WRENN, ESQ.

Nevada Bar No. 13285 GORDON REES SCULLY MANSUKHANI, LLP South 4th Street, Suite 1550 Las Vegas, Nevada 89101 Telephone: (702) 577-9300 Direct Line: (702) 577-9319 Facsimile: (702) 255-2858 E-Mail: [email protected] 8 [email protected] Attorneys for Defendant, MIDWEST FAMILY MUTUAL INSURANCE COMPANY UNITED STATES DISTRICT COURT DISTRICT OF NEVADA ARIZONA CIVIL CONSTRUCTORS, INC., a ) CASE NO. 2:20-cv-00010-JAD-DJA Nevada corporation, ) 14 ) STIPULATION AND ORDER TO Plaintiff, ) EXTEND MIDWEST FAMILY ) MUTUAL INSURANCE 16 vs. ) COMPANY’S DEADLINE TO ) FILE RESPONSE TO COLONY INSURANCE COMPANY; HDI ) COMPLAINT GLOBAL SPECIALTY SE, fka INTERNATIONAL ) INSURANCE COMPANY OF HANNOVER SE; ) MIDWEST FAMILY MUTUAL INSURANCE ) COMPANY; DOES I-X, inclusive; and ROE ) CORPORATIONS I-X, inclusive, ) ) 21 Defendants. ) ) Pursuant to Local Rules 6-1 and 7-1, Defendant MIDWEST FAMILY MUTUAL INSURANCE COMPANY (“Midwest”) and Plaintiff ARIZONA CIVIL CONSTRUCTORS, INC. (“ACC”) (collectively, the “Parties”), by and through their respective attorneys of record, stipulate as stated below.

STIPULATION 1. ACC filed a Complaint in the Eighth Judicial District Court, Clark County, || Nevada (“State Court”) on November 18, 2019.

2 2. On December 30, 2019, Defendant Colony Insurance Company filed a Notice of ||Removal in State Court. On the same day, a Notice of Removal was also filed with this Court.

4 ||ECF No. 1-1.

5 3. Prior to the removal, Midwest’s deadline to file a response to the Complaint was || December 30, 2019. Pursuant to FRCP 81(2)(c), Midwest’s response deadline became January || 8, 2020.

8 4. Midwest requests additional time to file its response up to and including || Wednesday, January 22, 2020.

10 5. ACC does not oppose Midwest’s requested extension.

11 6. Accordingly, Midwest will file its response to ACC’s Complaint on January 22, || 2020. £ = 13 7. This stipulation is not made for purposes of delay.

14 || DATED this 15th day of January, 2020.

3 15 || Respectfully Submitted By: wn = GORDON REES SCULLY MANSUKHANI, FENNEMORE CRAIG, P.C.

17 || LLP |) /s/ Dione C. Wrenn /s/ Chelsie A. Adams || ROBERT E. SCHUMACHER, ESQ. JOHN RANDALL JEFFERIES, ESQ.

Nevada Bar No. 7504 Nevada Bar No. 3512 || DIONE C. WRENN, ESQ. BRANDI M. PLANET, ESQ.

Nevada Bar No. 13285 Nevada Bar No. 11710 || 300 South 4" Street, Suite 1550 CHELSIE A. ADAMS, ESQ.

Las Vegas, Nevada 89101 Nevada Bar No. 13058 Attorneys for Defendant 300 South 4" Street, 14 Floor Midwest Family Mutual Insurance Co. Las Vegas, Nevada 89101 Attorneys for Plaintiff 94 Arizona Civil Constructors, Inc. 25 IT IS SO ORDERED 26 .

27 IE UNITED STATBHS MAGISTRATE JUDGE 28 DATED: January 21, 2020