`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF MICHIGAN
`
`
`TRINITY, INC d/b/a TRINITY
`TRANSPORTATION,
`Plaintiff/Counter-Defendant,
`v.
` A QUALITY STAFFING d/b/a
`ELITE MEDICAL STAFFING, and
`ELITE MEDICAL STAFFING, LLC,
`Defendants,
`ZURICH AMERICAN INSURANCE CO.,
`and AMERICAN GUARANTEE &
`LIABILITY INSURANCE COMPANY,
`
`Defendants/Counter Plaintiffs.
`
`
`BRIAN O’GALLAGHER
`TIMOTHY A. DIEMER
`
`JACOBS AND DIEMER, P.C.
`
`
`Bodell Bove LLC
`Attorneys for Plaintiff
`
`
`
`Attorneys for Zurich American
`500 Griswold Street
`
`
`
`Insurance Company and American
`Suite 2825
`
`
`
`
`Guarantee & Liability Insurance Co.
`Detroit, MI 48226
`
`
`
`2215 York Road
`Phone: (313) 965-1900
`
`
`Suite 515
`tad@jacobsdiemer.com
`
`
`Oak Brook, IL 60523
`
`
`
`
`
`
`
`Direct: (630) 382-4808
`
`
`
`
`
`
`
`
`Phone: (630) 382-4800
`
`
`
`
`
`
`
`Facsimile: (630) 468-2158
`
`
`
`
`
`
`
`BOGallagher@bodellbove.com
`
`
`
`
`
`
`
`
`
`
`
` Case No. 2:22-cv-10319-TGB-EAS
` Honorable Terrence G. Berg
`Magistrate Elizabeth A. Stafford
`
`
`STIPULATED ORDER
`EXTENDING ZURICH AND
`AGLIC’S TIME TO FILE REPLY
`BRIEFS IN SUPPORT OF
`OBJECTIONS TO MAGISTRATE
`JUDGE ELIZABETH STAFFORD’S
`ORDERS
`
`
`
`
`) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )
`
`
`
`{01854033.DOCX }
`
`
`
`Case 2:22-md-03034-TGB ECF No. 221, PageID.12223 Filed 01/23/24 Page 2 of 3
`
`NICOLE E. WILINSKI
`COLLINS EINHORN FARRELL PC
`Attorney for A Quality Staffing
`d/b/a Elite Medical Staffing, and
`Elite Medical Staffing, LLC
`4000 Town Center. 9th Floor
`Southfield, MI 48075
`Office: (248) 351-7168
`Cell: (248) 875-2220
`Fax: (248) 351-7169
`Nicole.Wilinski@ceflawyers.com
`
`
`
`
`
`RONALD L. CORNELL
`SK DETROIT LAW PARTNERS, P.C.
`Attorneys for Zurich American
`Insurance Company and American
`Guarantee & Liability Insurance Co.
`2000 Town Center #1500,
`Southfield, MI 48075
`Office: (248) 353-7620
`rcornell@skdetroitlaw.com
`
`
`
`STIPULATED ORDER EXTENDING ZURICH AND AGLIC’S TIME TO FILE
`REPLY BRIEF IN SUPPORT OF ZURICH AND AGLIC’S OBJECTIONS TO
`MAGISTRATE JUDGE ELIZABETH STAFFORD’S ORDER GRANTING THE
`PLAINTIFF’S MOTION TO QUASH NON‐PARTIES SUBPOENAS AND REPLY
`BRIEF IN SUPPORT OF ZURICH AND AGLIC’S OBJECTIONS TO
`MAGISTRATE JUDGE ELIZABETH STAFFORD’S ORDER DENYING ZURICH
`AND AGLIC’S MOTION FOR LEAVE TO FILE A THIRD‐PARTY COMPLAINT
`AGAINST OLD REPUBLIC INSURANCE COMPANY
`
`
`Upon the stipulation of the parties;
`The time period for Defendants/Counter-Plaintiffs ZURICH AMERICAN
`INSURANCE COMPANY and AMERICAN GUARANTEE & LIABILITY
`INSURANCE COMPANY’S to file the Reply Brief In Support Of Zurich and
`AGLIC’s Objections to Magistrate Judge Elizabeth Stafford’s Order Granting
`the Plaintiff’s Motion to Quash Non-Parties Subpoenas [ECF No. 96] and the
`Reply Brief In Support Of Zurich and AGLIC’s Objections to Magistrate Judge
`Elizabeth Stafford’s Order Denying Zurich and AGLIC’s Motion for Leave to
`File a Third-Party Complaint Against Old Republic Insurance Company [ECF
`No. 108] is EXTENDED an additional seven (7) days to January 31, 2024.
`
`Dated: January 23, 2024
`
`_s/Terrence G. Berg_________________
`
`
`
`
`
`
`
`TERRENCE G. BERG
`
`
`
`
`
`
`U.S. DISTRICT COURT JUDGE
`
`
`SO ORDERED.
`
`
`
`{01854033.DOCX }
`
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`
`
`January 17, 2024
`Stipulated and Agreed by:
` /s/ Brian A. O’Gallagher
`
`
`Brian A. O’Gallagher
`
`Attorney for Zurich American
`Insurance Company and
`American Guarantee
` /s/ Ronald L. Cornell, Jr.
`
`Ronald L. Cornell, Jr.
`
`
`Attorney for Zurich American
`Insurance Company and
`
`American Guarantee
`
`
`Case 2:22-md-03034-TGB ECF No. 221, PageID.12224 Filed 01/23/24 Page 3 of 3
`
`
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`
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`/s/ Timothy A. Diemer
`Timothy A. Diemer
`Attorney for Trinity, Inc.
`
`/s/ Nicole Wilinski
`
`Nicole Wilinski
`Attorney for A Quality Staffing
`and Elite Medical Staffing, LLC
`
`{01854033.DOCX }
`
`
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