Exemplar Notice of Stay

1-877-cmsynergy/1-877-267-9637
Hyde Mulvihill APC Lawyers
216 W. Foothill Blvd (91016) PO Box 1007
Monrovia CA 91017
(626) 358-7471 Fax: (626) 358-2894

This firm does not represent any insurance carrier, surety, insurance parent company, or related entity. (Actually, we handle insurance bad faith actions against insurance carriers.) This is information is provided as a courtesy, much like a phone book or directory. Please do not serve us with any documents for these insurers, as your service of process will be ineffective. It would be like serving the folks that publish the Yellow Pages.

This is an exemplar Notice of Stay. It must be put on pleading paper, and it must be filed by an attorney. Please consult with counsel before using this.

Attorneys for

SUPERIOR COURT OF THE STATE OF CALIFORNIA

COUNTY OF ___________________________

Plaintiff v. Defendants. _______________________________	) ) ) )) )) ) ) ) ) ) )))	Case No.: (CLIENT) NOTICE OF 60-DAY STAY ORDERED BY THE INSURANCE COMMISSIONER FOR THE COMMONWEALTH OF PENNSYLVANIA, DOCKET NO. 269 MD 2001; MAY 29, 2001 TO JULY 30, 2001 AND REQUEST THAT (HEARINGS/DATES ON CALENDAR/TRIAL) BE RESET TO AFTER LIFTING OF THE STAY
AND RELATED CROSS-ACTIONS

TO THE COURT AND TO ALL PARTIES AND THEIR ATTORNEYS OF RECORD HEREIN:

(Client) insurance carrier in this matter is Reliance Insurance Company[1]. On May 29, 2001, Reliance was placed into Rehabilitation by the Insurance Commissioner for the Commonwealth of Pennsylvania, in accordance with provisions of Article V of the Pennsylvania Insurance Department Act of 1921, Act of May 17, 1921, P.L. 789, as amended, 40 P.S. §§221.1-221.63.

In accordance with page 8 paragraph 22 of the order, “All actions currently pending against Reliance in the Courts of the Commonwealth of Pennsylvania are hereby stayed. All actions currently pending in the Courts of the Commonwealth of Pennsylvania or elsewhere against an insured of Reliance are stayed for 60 days or such additional time as the Rehabilitator may request. This Order shall not preclude any action from proceeding prior to the expiration of 60 days provided that the Rehabilitator and the parties to any such pending actions have so agreed to proceed.”

The full text of the Rehabilitation Order is available at www.cmsynergy.com.

DATED: _______________

____________________________________

CYNTHIA COULTER MULVIHILL

Attorneys for ___________________________

PROOF OF SERVICE BY MAIL

(1013A, 2015.5 C.C.P.)

STATE OF CALIFORNIA, COUNTY OF LOS ANGELES:

I am employed in the aforesaid county, State of California; I am over the age of eighteen years and not a party to the within action; my business address is: _____________________________________________________________

On _______________, I served the foregoing document described as: (CLIENT) NOTICE OF 60-DAY STAY ORDERED BY THE INSURANCE COMMISSIONER FOR THE COMMONWEALTH OF PENNSYLVANIA, DOCKET NO. 269 MD 2001; MAY 29, 2001 TO JULY 30, 2001 AND REQUEST THAT (HEARINGS/DATES ON CALENDAR/TRIAL) BE RESET TO AFTER LIFTING OF THE STAY on the interested parties in this action by placing a true copy thereof, enclosed in a sealed envelope with postage thereon fully prepaid, in the United States mail at Pasadena, California, addressed as follows:

*** SEE SERVICE LIST ***

[ ] BY MAIL: I am "readily familiar" with the firm's practice of collection and processing correspondence for mailing, that the mail would be deposited with the United States postal service on that same day with postage thereon fully prepaid at Glendale, California 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 date of deposit for mailing in affidavit.

[ ] BY FACSIMILE: The facsimile machine I used complied with Rule 2003(3), and the machine reported no error.

Transmission was sent from Fax No. ___________________ to all of the Fax Nos. of the parties on the attached Mailing List. Pursuant to Rule 2005(i), I caused the machine to print a record of each of the parties, which includes the date and time transmitted.

I certify (or declare), under penalty of perjury under the laws of the State of California, that the foregoing is true and correct. Executed on __________________, at ___________________.

_________________________________

_______________________

[1] This includes former Reliance subsidiaries Reliance National Indemnity Company, Reliance National Insurance Company, United Pacific Insurance Company, Reliance Direct Company, Reliance Surety Company, Reliance Universal Insurance Company, United Pacific Insurance Company of New York and Reliance Insurance Company of Illinois.