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PROTECTIVE ORD
Michael H. Ginsberg
Jones Day
500 Grant Street, Suite 4500
Pittsburgh , PA 15219
(412) 394-7919
Fax: (412) 394-7959
Email: mhginsberg@jonesday.com
LEAD ATTORNEY
PRO HAC VICE
ATTORNEY TO BE NOTICED
Paul J. Jalsevac
Jones Day
500 Grant Street, Suite 4500
Pittsburgh , PA 15219
(412) 394-9564
Fax: (412) 394-7959
Email: pjjalsevac@jonesday.com
LEAD ATTORNEY
PRO HAC VICE
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ATTORNEY TO BE NOTICED
Plaintiff
American Medical Response, Inc. represented by Michael E. Farnell
(See above for address)
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Michael H. Ginsberg
(See above for address)
LEAD ATTORNEY
PRO HAC VICE
ATTORNEY TO BE NOTICED
Paul J. Jalsevac
(See above for address)
LEAD ATTORNEY
PRO HAC VICE
ATTORNEY TO BE NOTICED
V.
Defendant
Ace American Insurance Company represented by Robert A. Meyers
Cozen O'Connor
1201 Third Avenue, Suite 5200
Seattle , WA 98101
(206) 340-1000
Fax: (206) 621-8783
Email: rmeyers@cozen.com
LEAD ATTORNEY
PRO HAC VICE
ATTORNEY TO BE NOTICED
Thomas M. Jones
Cozen & O'Connor
1201 Third Avenue, Suite 5200
Seattle , WA 98101-3071
(206) 340-1000
Fax: (206) 621-8783
Email: tjones@cozen.com
LEAD ATTORNEY
PRO HAC VICE
ATTORNEY TO BE NOTICED
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William F. Knowles
Cozen O'Connor
1201 Third Avenue, Suite 5200
Seattle , Wa 98101
(206) 340-1000
Fax: (206) 621-8783
Email: wknowles@cozen.com
ATTORNEY TO BE NOTICED
Defendant
National Union Fire Insurance represented by Jenny M. Churas
Company Of Pittsburgh, PA Johnson Andrews & Skinner PS
200 W. Thomas Street, Suite 500
Seattle , WA 98119
(206) 223-9248
Fax: (206) 623-9050
Email:
jenny.churas@johnsonandrews.com
LEAD ATTORNEY
PRO HAC VICE
ATTORNEY TO BE NOTICED
Lee S. Aronson
Schulte Anderson Downes Aronson
Bittner, PC
811 SW Naito Parkway
Suite 500
Portland , OR 97204-3379
(503) 223-4131
Fax: (503) 223-1346
Email: laronson@schulte-law.com
LEAD ATTORNEY
ATTORNEY TO BE NOTICED
Stephen G. Skinner
Johnson Andrews & Skinner, PS
200 West Thomas, Suite 500
Seattle , WA 98119
(206) 223-9248
Fax: (206) 623-9050
Email:
stephen.skinner@johnsonandrews.com
LEAD ATTORNEY
PRO HAC VICE
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ATTORNEY TO BE NOTICED
William F. Knowles
(See above for address)
ATTORNEY TO BE NOTICED
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11/05/2009 20 Motion for Extension of Time to Answer. Filed by National Union Fire
Insurance Company Of Pittsburgh, PA. (Aronson, Lee) (Entered: 11/05/2009)
11/05/2009 21 Declaration of Lee Aronson In Support. Filed by National Union Fire Insurance
Company Of Pittsburgh, PA. (Related document(s): Motion for Extension of
Time to Answer a Complaint/Petition 20 .) (Aronson, Lee) (Entered:
11/05/2009)
11/06/2009 22 Response Memorandum to Motion for Default Judgment Against Defendant
National Union Fire Insurance Company of Pittsburgh, Pa. 15 , Motion for
Entry of Default of Defendant National Union Fire Insurance Company of
Pittsburgh, Pa. 14 . Filed by National Union Fire Insurance Company Of
Pittsburgh, PA. (Aronson, Lee) (Entered: 11/06/2009)
11/09/2009 23 Order Granting Application for Special Admission Pro Hac Vice of Thomas M.
Jones for Ace American Insurance Company. Application Fee in amount of
$100 collected. Receipt No. 29881 issued. Signed on 11/9/09 by Judge Robert
E. Jones. (ljl) (Entered: 11/10/2009)
11/09/2009 24 Order Granting Application for Special Admission Pro Hac Vice of Robert A.
Meyers for Ace American Insurance Company. Application Fee in amount of
$100 collected. Receipt No. 29882 issued. Signed on 11/9/09 by Judge Robert
E. Jones. (ljl) (Entered: 11/10/2009)
11/20/2009 25 Corporate Disclosure Statement. Filed by National Union Fire Insurance
Company Of Pittsburgh, PA. (Aronson, Lee) (Entered: 11/20/2009)
11/20/2009 26 Answer to Complaint and Affirmative Defenses. Filed by National Union Fire
Insurance Company Of Pittsburgh, PA. (Aronson, Lee) (Entered: 11/20/2009)
12/03/2009 27 Motion Application for Admission Pro Hac Vice - Jenny Churas. Filed by
National Union Fire Insurance Company Of Pittsburgh, PA. (Aronson, Lee)
(Entered: 12/03/2009)
12/03/2009 28 Motion Application for Admission Pro Hac Vice - Stephen Skinner. Filed by
National Union Fire Insurance Company Of Pittsburgh, PA. (Aronson, Lee)
(Entered: 12/03/2009)
12/14/2009 29 RECORD OF ORDER by Judge Robert E. Jones: Plaintiff's motions (# 14 , 15
) for default judgment are DENIED. Defendant's motion (# 20 ) for extension of
time is MOOT. (eo) (Entered: 12/14/2009)
12/14/2009 30 Order Granting Application for Special Admission Pro Hac Vice of Stephen G.
Skinner for National Union Fire Insurance Company Of Pittsburgh, PA.
Application Fee in amount of $100 collected. Receipt No. 30421 issued. Signed
on 12/8/09 by Judge Robert E. Jones. (ljl) (Entered: 12/15/2009)
12/14/2009 31 Order Granting Application for Special Admission Pro Hac Vice of Jenny M.
Churas for National Union Fire Insurance Company Of Pittsburgh, PA.
Application Fee in amount of $100 collected. Receipt No. 30420 issued. Signed
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03/03/2010 43 Reply to Motion for Leave to File Amended Complaint/Petition 39 . Filed by all
plaintiffs. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit
D) (Jalsevac, Paul) (Entered: 03/03/2010)
03/16/2010 44 RECORD OF ORDER. Plaintiffs' motion 39 for leave to file amended complaint
is granted. The Scheduling Order issued on January 27, 2010, is amended as
follows: Date by which fact Discovery shall completed: 6/4/2010. Date by
which plaintiffs' Expert reports shall be filed: 6/25/10. Date by which
defendants' expert reports shall be filed: 7/23/10. Date by which expert
depositions shall be completed: 8/20/10. Date by which all Dispositive Motions
shall be filed: 9/10/2010. By Judge Robert E. Jones. (ljl) (Entered: 03/17/2010)
03/17/2010 45 Amended Complaint For Declaratory Relief and Breach of Contract Summons
issued as to ACE American Insurance Company and National Union Fire
Insurance Company of Pittsburgh, Pa..Filed by American Medical Response
Northwest, Inc., American Medical Response, Inc. against all defendants.
(Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3) (Jalsevac, Paul)
(Entered: 03/17/2010)
03/19/2010 46 Motion to Change or Transfer Venue Pursuant to 28 U.S.C. section 1404(a).
Oral Argument requested. Filed by Ace American Insurance Company.
(Knowles, William) (Entered: 03/19/2010)
03/19/2010 47 Brief in Support of ACE American Insurance Company's Motion to Transfer
Pursuant to 28 U.S.C. section 1404(a). Filed by Ace American Insurance
Company. (Related document(s): Motion to change/transfer venue 46 .)
(Attachments: # 1 Exhibit A to Brief in Support of ACE Motion to Transfer, # 2
Exhibit B to Brief in Support of ACE's Motion to Transfer, # 3 Exhibit C to
Brief in Support of ACE Motion to Transfer, # 4 Exhibit D to Brief in Support
of ACE Motion to Transfer, # 5 Exhibit E to Brief in Support of ACE Motion to
Transfer, # 6 Exhibit F to Brief in Support of ACE Motion to Transfer, # 7
Exhibit G to Brief in Support of ACE Motion to Transfer, # 8 Exhibit H to Brief
in Support of ACE Motion to Transfer) (Knowles, William) (Entered:
03/19/2010)
04/01/2010 48 Joint Motion for Protective Order. Filed by all parties. (Attachments: # 1
Proposed Order) (Jalsevac, Paul) (Entered: 04/01/2010)
04/02/2010 49 Response in Opposition to Motion to Change or Transfer Venue Pursuant to 28
U.S.C. section 1404(a) 46 . Filed by all plaintiffs. (Attachments: # 1 Exhibit A,
# 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7
Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12
Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Exhibit P, # 17
Exhibit Q, # 18 Exhibit R, # 19 Errata S, # 20 Exhibit T, # 21 Exhibit U, # 22
Errata V, # 23 Exhibit W, # 24 Exhibit X, # 25 Exhibit Y, # 26 Exhibit Z, # 27
Exhibit AA) (Jalsevac, Paul) (Entered: 04/02/2010)
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05/10/2010 61 Motion for Joinder Partial Joinder in Defendant National Union's Motion for
Summary Judgment. Oral Argument requested. Filed by Ace American
Insurance Company. (Knowles, William) (Entered: 05/10/2010)
05/10/2010 62 Memorandum in Opposition to Motion for Discovery and/or Inspection 55 .
Filed by all plaintiffs. (Attachments: # 1 Exhibit A, # 2 Exhibit B) (Jalsevac,
Paul) (Entered: 05/10/2010)
05/10/2010 63 Declaration of Michael H. Ginsberg In Support Of Opposition To Motion For
Protective Order. Filed by all plaintiffs. (Related document(s): Motion For
Discovery/Inspection, 55 .) (Jalsevac, Paul) (Entered: 05/10/2010)
05/14/2010 64 Declaration of Robert A. Meyers Supporting ACE American Insurance
Company's Partial Joinder in Defendant National Union's Motion for Summary
Judgment. Filed by Ace American Insurance Company. (Related document(s):
Motion for Joinder 61 .) (Attachments: # 1 Exhibit A to Declaration of Robert
Meyers Supporting ACE American Insurance Company's Partial Joinder in
National Union's Motion for Summary Judgment, # 2 Exhibit B to Declaration
of Robert Meyers Supporting ACE American's Partial Joinder in Defendant
National Union's Motion for Summary Judgment, # 3 Exhibit C to Declaration
of Robert Meyers Supporting ACE American's Partial Joinder in Defendant
National Union's Motion for Summary Judgment, # 4 Exhibit D to Declaration
of Robert Meyers Supporting ACE American's Partial Joinder in Defendant
National Union's Motion for Summary Judgment, # 5 Exhibit E to Declaration
of Robert Meyers Supporting ACE American's Partial Joinder in Defendant
National Union's Motion for Summary Judgment, # 6 Exhibit F to Declaration
of Robert Meyers Supporting ACE American's Partial Joinder in Defendant
National Union's Motion for Summary Judgment, # 7 Exhibit G to Declaration
of Robert Meyers Supporting ACE American's Partial Joinder in Defendant
National Union's Motion for Summary Judgment, # 8 Exhibit H to Declaration
of Robert Meyers Supporting ACE American's Partial Joinder in Defendant
National Union's Motion for Summary Judgment) (Meyers, Robert) (Entered:
05/14/2010)
05/14/2010 66 OPINION AND ORDER: Denying Defendants' Motion to Change or Transfer
Venue (Related Doc # 46 )(and #50). Signed on 5/14/10 by Judge Robert E.
Jones. (ljl) (Entered: 05/17/2010)
05/17/2010 65 Unopposed Motion for Extension of Time to File a Response/Reply to Motion
for Summary Judgment 56 . Filed by all plaintiffs. (Jalsevac, Paul) (Entered:
05/17/2010)
06/01/2010 67 RECORD OF ORDER by Judge Robert E. Jones: GRANTING Plaintiffs'
unopposed Motion for Extension of Time to File Response/Reply (# 65 ) as
follows: Plaintiffs' response to Defendant National Union's motion for summary
judgment is due by 6/3/2010. (eo) (Entered: 06/01/2010)
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06/02/2010 68 Motion for Protective Order re: Depositions. Filed by National Union Fire
Insurance Company Of Pittsburgh, PA. (Skinner, Stephen) (Entered:
06/02/2010)
06/02/2010 69 Memorandum in Support of National Union's Motion for Protective Order re:
Depositions. Filed by National Union Fire Insurance Company Of Pittsburgh,
PA. (Related document(s): Motion for Protective Order 68 .) (Skinner, Stephen)
(Entered: 06/02/2010)
06/02/2010 70 Declaration of Stephen G. Skinner in Support of National Union's Motion for
Protective Order re: Depositions. Filed by National Union Fire Insurance
Company Of Pittsburgh, PA. (Related document(s): Motion for Protective Order
68 .) (Skinner, Stephen) (Entered: 06/02/2010)
06/03/2010 71 Response in Opposition to Motion for Summary Judgment 56 . Filed by all
plaintiffs. (Jalsevac, Paul) (Entered: 06/03/2010)
06/03/2010 72 Response to Concise Statement of Material Facts regarding Motion for
Summary Judgment 56 . Filed by all plaintiffs. (Jalsevac, Paul) (Entered:
06/03/2010)
06/03/2010 73 Declaration of Randy Lauer. Filed by all plaintiffs. (Related document(s):
Response in Opposition to Motion 71 .) (Attachments: # 1 Exhibit 1, # 2 Exhibit
2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8
Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13
Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15, # 16 Exhibit 16, # 17 Exhibit 17)
(Jalsevac, Paul) (Entered: 06/03/2010)
06/03/2010 74 Declaration of Michael H. Ginsberg. Filed by all plaintiffs. (Related
document(s): Response in Opposition to Motion 71 .) (Attachments: # 1 Exhibit
1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7
Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12
Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14) (Jalsevac, Paul) (Entered:
06/03/2010)
06/03/2010 75 Declaration of Julie A. Mederos. Filed by all plaintiffs. (Related document(s):
Response in Opposition to Motion 71 .) (Attachments: # 1 Exhibit 1, # 2 Errata
2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8
Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13
Exhibit 13, # 14 Exhibit 14 - Part 1, # 15 Exhibit 14-Pt.2, # 16 Exhibit 15, # 17
Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18, # 20 Exhibit 19, # 21 Exhibit 20, #
22 Exhibit 21, # 23 Exhibit 22, # 24 Exhibit 23, # 25 Exhibit 24, # 26 Exhibit
25, # 27 Exhibit 26, # 28 Exhibit 27, # 29 Exhibit 28) (Jalsevac, Paul) (Entered:
06/03/2010)
06/03/2010 76 Declaration of Ronald W. Thackery. Filed by all plaintiffs. (Related
document(s): Response in Opposition to Motion 71 .) (Attachments: # 1 Exhibit
1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7
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