United States Department of Justice vs. Rajendra Jamnadas

Filing 429

STIPULATION and ORDER -GRANTED. #415 MOTION for SUMMARY JUDGMENT currently set for 1/13/10 has been CONTINUED to 2/11/2010 at 08:30 AM in Courtroom 4 (LJO) before District Judge Lawrence J. O'Neill signed by District Judge Lawrence J. O'Neill on December 17, 2009. (Lira, I)

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8001 Folsom Boulevard, Suite 100 Sacramento, California 95826 Telephone: [phone]

Eric Grant (Bar No. 151064) [e-mail] Hicks Thomas LLP 8001 Folsom Boulevard, Suite 100 Sacramento, California 95826 Telephone: [phone] Facsimile: [phone] John B. Thomas (pro hac vice) [e-mail] Brian M. Keller (pro hac vice) [e-mail] Hicks Thomas LLP 700 Louisiana Street, Suite 2000 Houston, Texas 77002 Telephone: [phone] Facsimile: [phone] Counsel for Third-Party Defendant R.R. STREET & CO. INC. UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA FRESNO DIVISION ) ) Plaintiff, ) ) v. ) ) STEPHEN C. LYON, et al., ) ) Defendants/Third-Party Plaintiffs, ) ) v. ) ) THE DOW CHEMICAL COMPANY, et al., ) ) Third-Party Defendants. ) ) AND ALL RELATED CROSS-CLAIMS ) AND THIRD-PARTY CLAIMS. ) ) UNITED STATES OF AMERICA, No. 1:07-cv-00491-LJO-GSA
JOINT REQUEST FOR CONTINUANCE OF HEARING ON THIRD-PARTY DEFENDANT R.R. STREET & CO. INC.'S MOTION FOR SUMMARY JUDGMENT AS TO M.B.L. INC. [L.R. 230(f)]

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Hearing Date: Time: Courtroom: Judge:

January 13, 2010 8:30 a.m. 4 Hon. Lawrence J. O'Neill

Pursuant to Local Rule 230(f), Third-Party Defendant R.R. Street & Co. Inc. ("Street") and Third-Party Defendant/Cross-Claimant M.B.L. Inc. ("MBL") respectfully request a continuance of the hearing on Street's pending motion for summary judgment against MBL. In support of this request, Street and MBL would show the following:
{00133865.DOC}

1 Joint Request for Continuance of Hearing on R.R. Street & Co. Inc.'s Motion for Summary Judgment as to M.B.L. Inc.

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8001 Folsom Boulevard, Suite 100 Sacramento, California 95826 Telephone: [phone]

1.

Street filed its motion for summary judgment on December 8, 2009 and properly set

the motion for hearing on January 5, 2010 (Doc. 415). 2. On December 9, 2009, the Court sua sponte continued that hearing until January 13,

2010 (Doc. 420). 3. MBL has approached Street requesting an approximate 30-day continuance of the

hearing, and Street is amenable to such request. 4. Continuing the scheduled hearing until Thursday, February 11, 2010, at 8:30 a.m.,

would accommodate MBL's request. 5. 2010. 6. Although MBL does not waive any right to request an additional continuance from MBL has agreed to file its opposition to Street's motion on or before January 22,

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the Court, Street respectfully informs MBL and the Court that Street will oppose any additional continuance. Therefore, Street and MBL request that the hearing on Street's motion for summary judgment against MBL be continued until Thursday, February 11, 2010, at 8:30 a.m., and that any opposition to the motion be filed on or before January 22, 2010. Dated: December 16, 2009. Respectfully submitted, /s/ Eric Grant Eric Grant John B. Thomas Brian M. Keller Hicks Thomas LLP Counsel for Third-Party Defendant R.R. STREET & CO. INC. HAMRICK & EVANS, LLP By: /s/ Douglas K. Lackey (as authorized on this date) A. RAYMOND HAMRICK, III DOUGLAS K. LACKEY Attorneys for THIRD PARTY DEFENDANT M.B.L. INC.
{00133865.DOC}

2 Joint Request for Continuance of Hearing on R.R. Street & Co. Inc.'s Motion for Summary Judgment as to M.B.L. Inc.

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8001 Folsom Boulevard, Suite 100 Sacramento, California 95826 Telephone: [phone]

IT IS SO ORDERED.

Date:

December 17, 2009

_/s/ Lawrence J. O'Neill Honorable Lawrence J. O'Neill United States District Judge

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{00133865.DOC}

3 Joint Request for Continuance of Hearing on R.R. Street & Co. Inc.'s Motion for Summary Judgment as to M.B.L. Inc.