Desrosiers v Hartford Fire Ins., et al

Filing 37

STIPULATION and ORDER signed by Judge Morrison C. England, Jr. on 10/4/2012 ORDERING 34 that the deadline of 11/15/2012 for hearing dispositive motions shall be CONTINUED to 12/13/2012. (Reader, L)

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1 2 3 CHRISTOPHER H. WHELAN, INC. Christopher H. Whelan (SBN 80823) 11246 Gold Express Drive, Suite 100 Gold River, California 95670 Telephone: (916) 635-5577 Facsimile: (916) 635-9159 4 5 Attorneys for Plaintiff, LINDA K. DESROSIERS 6 7 8 9 JACKSON LEWIS LLP ROBERT J. SCHNACK (SBN 191987) JERRY J. DESCHLER JR. (SBN 215691) 801 K Street, Suite 2300 Sacramento, CA 95814 Telephone: (916) 341-0404 Facsimile: (916) 341-0141 10 11 12 Attorneys for Defendants THE HARTFORD aka HARTFORD FIRE INS. CO. And HARTFORD FINANCIAL SERVICES GROUP, INC. 13 UNITED STATES DISTRICT COURT 14 EASTERN DISTRICT OF CALIFORNIA 15 SACRAMENTO DIVISION 16 17 18 LINDA K. DESROSIERS, Plaintiff, 19 20 v. 23 THE HARTFORD aka HARTFORD FIRE INS. CO., HARTFORD FINANCIAL SERVICES GROUP, INC., and DOES 1 through 20, inclusive, 24 Defendants. _______________________________ 21 22 ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 2:09-cv-02057-MCE-GGH STIPULATION AND JOINT APPLICATION TO CONTINUE DEADLINE FOR HEARING DISPOSITIVE MOTIONS DUE TO SCHEDULE CONFLICTS; ORDER THEREON Complaint Filed: Trial Date: January 26, 2009 July 29, 2013 25 26 27 28 Pursuant to Federal Rule of Civil Procedure 16(b)(4), and for good cause shown, Plaintiff Linda K. DesRosiers ("Plaintiff") and Defendants The Hartford aka Hartford Fire Ins. Co. and 1 1 Hartford Financial Services Group, Inc. (collectively hereinafter "Defendants"), through their 2 respective counsel of record, hereby stipulate and jointly request that the Court vacate the present 3 deadline of November 15, 2012 for hearing dispositive motions and continue the deadline for 4 hearing dispositive motions approximately 28 days. This request will not impact the trial date or 5 any other deadlines, and will still allow dispositive motions to be heard approximately seven 6 months before trial. 7 THE PARTIES HEREBY STIPULATE AS FOLLOWS: 8 WHEREAS this matter is set for trial on July 29, 2013. 9 WHEREAS the deadline for the Court to hear dispositive motions is November 15, 2012. 10 WHEREAS counsel for Plaintiff has a number of commitments that will make it impossible 11 to prepare a response to the extensive summary judgment to be filed in this action including a series 12 of events that cannot be rescheduled that will require him to be out of town, in addition to mediation 13 and a recently scheduled appellate oral argument in a complex media defendant defamation case. 14 Consequently, good cause exists for continuing the deadline to hear dispositive motions as 15 follows: The deadline of November 15, 2012 for hearing dispositive motions shall be continued to 16 December 13, 2012. 17 18 IT IS SO STIPULATED. 19 Dated: September 25, 2012 CHRISTOPHER H. WHELAN, INC. 20 By: _____/S/________________ 21 Christopher H. Whelan Attorneys for Plaintiff LINDA K. DESROSIERS 22 23 24 25 26 27 28 2 1 JACKSON LEWIS LLP Dated: September 25, 2012 2 3 By:_/S/___________________ 4 ROBERT J. SCHNACK JERRY J. DESCHLER, JR. 5 6 Attorneys for Defendants THE HARTFORD aka HARTFORD FIRE INS.CO and HARTFORD FINANCIAL SERVICES GROUP, INC. 7 8 9 10 11 12 ORDER 13 14 Having reviewed the parties' stipulation, and good cause appearing therefore, 15 IT IS HEREBY ORDERED that the deadline of November 15, 2012 for hearing dispositive motions 16 shall be continued to December 13, 2012. 17 18 19 20 Dated: October 4, 2012 ________________________________ MORRISON C. ENGLAND, JR. UNITED STATES DISTRICT JUDGE 21 22 23 24 25 26 27 28 3

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