On February 17, 2020 a
Exhibit,Appendix
was filed
involving a dispute between
Western Beef Properties, Inc.,
Western Beef St Rentals, Llc,
and
Ace American Insurance Company,
Deception 2017 Pilot,
Time Warner Inc.,
Warner Bros. Entertainment Inc.,
Warner Bros. Television, A Division Of Wb Studio Enterprises Inc.,
Wb Studio Enterprises Inc.,
for Commercial - Insurance
in the District Court of New York County.
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FILED: NEW YORK COUNTY CLERK 03/23/2022 08:56 AM INDEX NO. 651051/2020
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 03/23/2022
EXHIBIT A
FILED: NEW YORK COUNTY CLERK 03/23/2022 08:56 AM INDEX NO. 651051/2020
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 03/23/2022
SUPREME COURT OF THE STATE OF NEW YORK
COUNTY OF NEW YORK
WESTERN BEEF PROPERTIES, INC., and
WESTERN BEEF ST RENTALS, LLC., Index No. 651051/2020
Plaintiff,
v. DISCOVERY
STIPULATION
ACE AMERICAN INSURANCE COMPANY,
WARNER BROS. ENTERTAINMENT INC.,
WARNER BROS TELEVISION, A DIVISION OF
WB STUDIO ENTERPRISES INC., WB STUDIO
ENTERPRISES INC., TIME WARNER INC., and
DECEPTION 2017 PILOT.
Defendants.
IT IS HEREBY STIPULATED AND AGREED by and between the undersigned
attorneys for the parties herein:
1. That all depositions shall be completed by July 18, 2022;
2. That all fact discovery shall be completed by August 31, 2022;
3. Plaintiff shall file a note of issue/certificate of readiness on or before September 21,
2022. A copy of this order, an affirmation stating that the terms of the order have been
complied with, and an affidavit of service of the affirmation and note of issue shall be
served and filed with the notice of issue on or before said date.
IT IS FURTHER STIPULATED AND AGREED that all parties reserve the right to
conduct further discovery per the CPLR.
IT IS FURTHER STIPULATED AND AGREED that this stipulation may be executed
in counterparts and that a facsimile or electronic signature shall have the same binding effect on
all parties hereto as an original signature.
FILED: NEW YORK COUNTY CLERK 03/23/2022 08:56 AM INDEX NO. 651051/2020
NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 03/23/2022
Dated: March 21, 2022
FLEISCHNER POTASH LLP
By:/s/ Marianne G. May
Marianne G. May, Esq.
By: /s/ Alexandra E. Rigney, Esq.______ Daniel B. Palmer, Esq.
Alexandra E. Rigney, Esq.
Attorneys for Plaintiffs
45 Broadway 23rd Floor Attorneys for Defendant,
New York, New York 10006 ACE American Insurance Company
Tel: (646) 520-4200 340 Mt. Kemble Avenue, Suite 300
E-mail: arigney@fp.law Morristown, New Jersey 07960
Tel: (973) 210-6700
Fax: (973) 210-6701
The Chrysler Building
405 Lexington Avenue, 16th Floor
New York, New York 10174
CLYDE & CO US LLP
LEWIS BRISBOIS BISGAARD & SMITH LLP
By: /s/ Steven R. Montgomery
Steven R. Montgomery
Attorneys for Defendants Warner Bros.
Entertainment, Inc., Warner Bros.
Television, a Division of WB Studio
Enterprises, Inc. and WB Studio Enterprises, Inc.
77 Water Street — Suite 2100
New York, New York 10005
Tel: (212) 232-1500
SO ORDERED:
_____________________________
J.S.C.
2
Document Filed Date
March 23, 2022
Case Filing Date
February 17, 2020
Category
Commercial - Insurance
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FILED: NEW YORK COUNTY CLERK 03/23/2022 08:56 AM INDEX NO. 651051/2020 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 03/23/2022 EXHIBIT A FILED: NEW YORK COUNTY CLERK 03/23/2022 08:56 AM INDEX NO. 651051/2020 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 03/23/2022 SUPREME COURT OF THE STATE OF NEW YORK COUNTY OF NEW YORK WESTERN BEEF PROPERTIES, INC., and WESTERN BEEF ST RENTALS, LLC., Index No. 651051/2020 Plaintiff, v. DISCOVERY STIPULATION ACE AMERICAN INSURANCE COMPANY, WARNER BROS. ENTERTAINMENT INC., WARNER BROS TELEVISION, A DIVISION OF WB STUDIO ENTERPRISES INC., WB STUDIO ENTERPRISES INC., TIME WARNER INC., and DECEPTION 2017 PILOT. Defendants. IT IS HEREBY STIPULATED AND AGREED by and between the undersigned attorneys for the parties herein: 1. That all depositions shall be completed by July 18, 2022; 2. That all fact discovery shall be completed by August 31, 2022; 3. Plaintiff shall file a note of issue/certificate of readiness on or before September 21, 2022. A copy of this order, an affirmation stating that the terms of the order have been complied with, and an affidavit of service of the affirmation and note of issue shall be served and filed with the notice of issue on or before said date. IT IS FURTHER STIPULATED AND AGREED that all parties reserve the right to conduct further discovery per the CPLR. IT IS FURTHER STIPULATED AND AGREED that this stipulation may be executed in counterparts and that a facsimile or electronic signature shall have the same binding effect on all parties hereto as an original signature. FILED: NEW YORK COUNTY CLERK 03/23/2022 08:56 AM INDEX NO. 651051/2020 NYSCEF DOC. NO. 26 RECEIVED NYSCEF: 03/23/2022 Dated: March 21, 2022 FLEISCHNER POTASH LLP By:/s/ Marianne G. May Marianne G. May, Esq. By: /s/ Alexandra E. Rigney, Esq.______ Daniel B. Palmer, Esq. Alexandra E. Rigney, Esq. Attorneys for Plaintiffs 45 Broadway 23rd Floor Attorneys for Defendant, New York, New York 10006 ACE American Insurance Company Tel: (646) 520-4200 340 Mt. Kemble Avenue, Suite 300 E-mail: arigney@fp.law Morristown, New Jersey 07960 Tel: (973) 210-6700 Fax: (973) 210-6701 The Chrysler Building 405 Lexington Avenue, 16th Floor New York, New York 10174 CLYDE & CO US LLP LEWIS BRISBOIS BISGAARD & SMITH LLP By: /s/ Steven R. Montgomery Steven R. Montgomery Attorneys for Defendants Warner Bros. Entertainment, Inc., Warner Bros. Television, a Division of WB Studio Enterprises, Inc. and WB Studio Enterprises, Inc. 77 Water Street — Suite 2100 New York, New York 10005 Tel: (212) 232-1500 SO ORDERED: _____________________________ J.S.C. 2