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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1 2 3 4 5 6 7 8 9 10 11 8001 Folsom Boulevard, Suite 100 Sacramento, California 95826 Telephone: (916) 388-0833 Eric Grant (Bar No. 151064) grant@hicks-thomas.com Hicks Thomas LLP 8001 Folsom Boulevard, Suite 100 Sacramento, California 95826 Telephone: (916) 388-0833 Facsimile: (916) 691-3261 John B. Thomas (pro hac vice) jthomas@hicks-thomas.com Brian M. Keller (pro hac vice) bkeller@hicks-thomas.com Hicks Thomas LLP 700 Louisiana Street, Suite 2000 Houston, Texas 77002 Telephone: (713) 547-9100 Facsimile: (713) 547-9150 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)] HICKS THOMAS LLP 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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. 1 2 3 4 5 6 7 8 9 10 11 8001 Folsom Boulevard, Suite 100 Sacramento, California 95826 Telephone: (916) 388-0833 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, HICKS THOMAS LLP 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 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. 1 2 3 4 5 6 7 8 9 10 11 8001 Folsom Boulevard, Suite 100 Sacramento, California 95826 Telephone: (916) 388-0833 IT IS SO ORDERED. Date: December 17, 2009 _/s/ Lawrence J. O'Neill Honorable Lawrence J. O'Neill United States District Judge HICKS THOMAS LLP 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 {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.

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