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Page 1 ACOA
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Jun-17-2013 1:28 pm
Case Number: CGC-13-531155
Filing Date: Jun-17-2013 1:27
Filed by: ANNA TORRES
Juke Box: 001 Image: 04094275
STIPULATION
UNITED STATES FIRE INSURANCE COMPANY VS. THOMAS DEE
ENGINEERING COMPANY, INC., F/K/A DEE
001004094275
Instructions:
Please place this sheet on top of the document to be scanned.Page 2 EMBARCADERO CENTER WEST
GORDON & REES, LLP
ATTORNEYS AT LAW
275 BATTERY STREET, TWENTIETH FLOOR
BY FAX
ND
~
SAN FRANCISCO, CA 941114
oO ON ODO OM. & WwW TD =a
N pO Nh NH AS BO RO =e ak ok Ok eek
NO
a
SARA M. THORPE (SBN: 146529)
GORDON & REES LLP
Embarcadero Center West San Francisco Cnn:
275 Battery Street, Twentieth Floor Mnetseo County Superior Court
San Francisco, California 94111 JUN 1 / 201 3
Telephone: (415) 986-5900
Facsimile: (415) 986-8054 CLERK OF COURT
Attorneys for Plaintiff UNITED STATES BY: tie We if AOL (ou
FIRE INSURANCE COMPANY ~ Deputy Clerk
SUPERIOR COURT OF CALIFORNIA —
COUNTY OF SAN FRANCISCO
UNITED STATES FIRE INSURANCE
COMPANY, a New York corporation,
Plaintiff,
CASE NO. CGC-13-531155:
)
)
STIPULATION TO EXTEND TIME
FOR DEFENDANT TO RESPOND TO
COMPLAINT
vs.
) ICAL. RULES OF COURT 3.110(f);
THOMAS DEE ENGINEERING )
COMPANY, INC.; fka DEE ENGINEERING )
CO., a California corporation,
)
)
Local Rule 3. .1(B)]
Defendant.
Pursuant to California Rules of Court, Rule 3.1 10(f) and Local Rule 3. 1(B), which
allow parties to request by application to extend the time to respond to a complaint,
Plaintiff UNITED STATES FIRE INSURANCE COMPANY(“U.S. FIRE”) and Defendant
THOMAS DEE ENGINEERING COMPANY, INC (“DEE”) stipulate and agree that:
1. U.S. FIRE filed and served its Complaint on Dee.
2. ‘The parties are attempting to resolve their dispute prior to incurring
expenses litigating this matter.
3. The parties agreed that_Dee could have additional time (to June 24, 2013)
to respond to the Complaint.
4. The parties believe they will be able to determine within the next 60 days
whether they will be able to resolve their dispute.
. . 1 .
STIPULATION TO EXTEND TIME WHICH DEFENDANT HAS TO RESPOND TO COMPLAINT
PURSUANT TO CALIFORNIA RULES OF COURT, RULE 3.110(f) AND LOCAL RULE 3.1(B)Page 3 g
S
Be
seh
ase
Bege
ei ol
Rae
ee
oO «
SAN FRANCISCO, CA 94111
—_
“ON NM NO NY NY NY ND DM DB @&@ ow Ba ow An ow oa a
ON OA FeO HM B= DH AN AGAR EE BH D2. 5FGwHeEN Da aan
5. Thus, DEE should have until August 26, 2013 to respond to the
Complaint.
Dated: June (7 2013
Dated: June/ 2, 2013
STIPULATION TO EXTEND TIME WHICH DEFENDANT HAS TO RESPOND TO COMPLAINT
PURSUANT TO CALIFORNIA RULES OF COURT, RULE 3.110(f) AND LOCAL RULE 3.1(B)
RVRS/1088 70371590087 70-1
\
PEALE LL.
2
_ GORDON & REES LLP
-SARA M. THORP
Attorneys for Plaintiff
UNITED STATES FIRE INSURANCE
COMPANY
HANSON BRIDGET LLP
LINDA E. KLAMM ~
Attorneys for Defendant
| IOMAS DEE ENGINEERING CO.,Page 4 Oo CO TI NW
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Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
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RVRS/1085703/15929525v.1
PROOF OF SERVICE
US Fire Ins. Co. v. Thomas Dee Engineering Co.
San Francisco Superior Court, Case No. CGC-13-531155
I am a resident of the State of California, over the age of eighteen years, and not a party
to the within action. My business address is: Gordon & Rees LLP 275 Battery Street, Suite
2000, San Francisco, CA 94111. On the date noted below, I served the within documents:
* Ex Parte Application for Extension of Time to Serve Pleading
and Order Extending Time;
* Stipulation to Extend Time for Defendant to Respond to Complaint
Oo by transmitting via facsimile the document(s) listed above to the fax number(s) set
forth below on this date before 5:00 p.m.
CT by personally delivering the document(s) listed above to the person(s) at the
address(es) set forth below.
by placing the document(s) listed above in a sealed envelope with postage thereon
fully prepaid, in United States mail in the State of California at San Francisco,
addressed as set forth below.
Linda E. Klamm Attorneys for Def. Thomas Dee Enginr:
Hanson Bridget LLP
425 Market Street, 26" Floor (415) 777-3200 ph
San Francisco, CA 94105 (415) 541-9366 fax
Iklamm@hansonbridgett.com
I am readily familiar with the firm’s practice of collection and processing correspondence
for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same
day with postage thereon fully prepaid in the ordinary course of business. I am aware that on
motion of the party served, service is presumed invalid if postal cancellation date or postage
meter date is more than one day after the date of deposit for mailing in affidavit.
I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
I declare that I am employed in the office of a member of the Bar of this court at whose
direction the service was made.
Executed on June 17, 2013 at San Francisco, California.
Pawt ade
} Pamela Chdy
PDF Page 1
PlainSite Cover Page
PDF Page 2
ACOA
SUPERIOR COURT OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Document Scanning Lead Sheet
Jun-17-2013 1:28 pm
Case Number: CGC-13-531155
Filing Date: Jun-17-2013 1:27
Filed by: ANNA TORRES
Juke Box: 001 Image: 04094275
STIPULATION
UNITED STATES FIRE INSURANCE COMPANY VS. THOMAS DEE
ENGINEERING COMPANY, INC., F/K/A DEE
001004094275
Instructions:
Please place this sheet on top of the document to be scanned.
PDF Page 3
EMBARCADERO CENTER WEST
GORDON & REES, LLP
ATTORNEYS AT LAW
275 BATTERY STREET, TWENTIETH FLOOR
BY FAX
ND
~
SAN FRANCISCO, CA 941114
oO ON ODO OM. & WwW TD =a
N pO Nh NH AS BO RO =e ak ok Ok eek
NO
a
SARA M. THORPE (SBN: 146529)
GORDON & REES LLP
Embarcadero Center West San Francisco Cnn:
275 Battery Street, Twentieth Floor Mnetseo County Superior Court
San Francisco, California 94111 JUN 1 / 201 3
Telephone: (415) 986-5900
Facsimile: (415) 986-8054 CLERK OF COURT
Attorneys for Plaintiff UNITED STATES BY: tie We if AOL (ou
FIRE INSURANCE COMPANY ~ Deputy Clerk
SUPERIOR COURT OF CALIFORNIA —
COUNTY OF SAN FRANCISCO
UNITED STATES FIRE INSURANCE
COMPANY, a New York corporation,
Plaintiff,
CASE NO. CGC-13-531155:
)
)
STIPULATION TO EXTEND TIME
FOR DEFENDANT TO RESPOND TO
COMPLAINT
vs.
) ICAL. RULES OF COURT 3.110(f);
THOMAS DEE ENGINEERING )
COMPANY, INC.; fka DEE ENGINEERING )
CO., a California corporation,
)
)
Local Rule 3. .1(B)]
Defendant.
Pursuant to California Rules of Court, Rule 3.1 10(f) and Local Rule 3. 1(B), which
allow parties to request by application to extend the time to respond to a complaint,
Plaintiff UNITED STATES FIRE INSURANCE COMPANY(“U.S. FIRE”) and Defendant
THOMAS DEE ENGINEERING COMPANY, INC (“DEE”) stipulate and agree that:
1. U.S. FIRE filed and served its Complaint on Dee.
2. ‘The parties are attempting to resolve their dispute prior to incurring
expenses litigating this matter.
3. The parties agreed that_Dee could have additional time (to June 24, 2013)
to respond to the Complaint.
4. The parties believe they will be able to determine within the next 60 days
whether they will be able to resolve their dispute.
. . 1 .
STIPULATION TO EXTEND TIME WHICH DEFENDANT HAS TO RESPOND TO COMPLAINT
PURSUANT TO CALIFORNIA RULES OF COURT, RULE 3.110(f) AND LOCAL RULE 3.1(B)
PDF Page 4
g
S
Be
seh
ase
Bege
ei ol
Rae
ee
oO «
SAN FRANCISCO, CA 94111
—_
“ON NM NO NY NY NY ND DM DB @&@ ow Ba ow An ow oa a
ON OA FeO HM B= DH AN AGAR EE BH D2. 5FGwHeEN Da aan
5. Thus, DEE should have until August 26, 2013 to respond to the
Complaint.
Dated: June (7 2013
Dated: June/ 2, 2013
STIPULATION TO EXTEND TIME WHICH DEFENDANT HAS TO RESPOND TO COMPLAINT
PURSUANT TO CALIFORNIA RULES OF COURT, RULE 3.110(f) AND LOCAL RULE 3.1(B)
RVRS/1088 70371590087 70-1
\
PEALE LL.
2
_ GORDON & REES LLP
-SARA M. THORP
Attorneys for Plaintiff
UNITED STATES FIRE INSURANCE
COMPANY
HANSON BRIDGET LLP
LINDA E. KLAMM ~
Attorneys for Defendant
| IOMAS DEE ENGINEERING CO.,
PDF Page 5
Oo CO TI NW
10
11
12
13
14
15
16
Gordon & Rees LLP
275 Battery Street, Suite 2000
San Francisco, CA 94111
17
18
19
20
21
22
23
24
25
26
27
28
RVRS/1085703/15929525v.1
PROOF OF SERVICE
US Fire Ins. Co. v. Thomas Dee Engineering Co.
San Francisco Superior Court, Case No. CGC-13-531155
I am a resident of the State of California, over the age of eighteen years, and not a party
to the within action. My business address is: Gordon & Rees LLP 275 Battery Street, Suite
2000, San Francisco, CA 94111. On the date noted below, I served the within documents:
* Ex Parte Application for Extension of Time to Serve Pleading
and Order Extending Time;
* Stipulation to Extend Time for Defendant to Respond to Complaint
Oo by transmitting via facsimile the document(s) listed above to the fax number(s) set
forth below on this date before 5:00 p.m.
CT by personally delivering the document(s) listed above to the person(s) at the
address(es) set forth below.
by placing the document(s) listed above in a sealed envelope with postage thereon
fully prepaid, in United States mail in the State of California at San Francisco,
addressed as set forth below.
Linda E. Klamm Attorneys for Def. Thomas Dee Enginr:
Hanson Bridget LLP
425 Market Street, 26" Floor (415) 777-3200 ph
San Francisco, CA 94105 (415) 541-9366 fax
Iklamm@hansonbridgett.com
I am readily familiar with the firm’s practice of collection and processing correspondence
for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same
day with postage thereon fully prepaid in the ordinary course of business. I am aware that on
motion of the party served, service is presumed invalid if postal cancellation date or postage
meter date is more than one day after the date of deposit for mailing in affidavit.
I declare under penalty of perjury under the laws of the State of California that the above
is true and correct.
I declare that I am employed in the office of a member of the Bar of this court at whose
direction the service was made.
Executed on June 17, 2013 at San Francisco, California.
Pawt ade
} Pamela Chdy