Bel Air Mart et al v. Arnold Cleaners, Inc. et al

Filing 170

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr on 1/22/13: The deadline for Plaintiffs to respond to the Counter and Cross-Claims is hereby extended from January 25, 2013, up to and including April 30, 2013. (Kaminski, H)

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DOWNEY BRAND LLP
ROBERT P. SORAN (Bar No. 169577)
ELIZABETH B. STALLARD (Bar No. 221445)
OLIVIA M. WRIGHT (Bar No. 240200)
621 Capitol Mall, 18th Floor
Sacramento, CA 95814-4731
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Plaintiff and Counterdefendant
BEL AIR MARKET, a California Corporation

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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BEL AIR MART, a California corporation
and WONG FAMILY INVESTORS, L.P.,
Plaintiffs,

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v.

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Case No. 2:10-CV-02392 MCE-EFB
THIRD STIPULATION TO EXTEND TIME
TO RESPOND TO THE COUNTER AND
CROSS-CLAIM OF THE ESTATE OF
RONALD G. ARMSTRONG, DECEASED;
ORDER

ARNOLD CLEANERS, INC.; et al.,
Defendants.

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AND RELATED CROSS-ACTIONS

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TO THE COURT, ALL PARTIES, AND THEIR COUNSEL OF RECORD HEREIN:

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Pursuant to Local Rule 144(a), Defendant Century Indemnity Company, as successor to

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CCI Insurance Company, as successor to Insurance Company of North America, as alleged

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insurer of The Estate of Ronald G. Armstrong, Deceased, pursuant to California Probate Code

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section 550 et seq., by and through its counsel of record Farheena A. Habib of Bassi Edlin Huie &

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Blum LLP, and Plaintiffs Bel Air Mart, a California corporation, by and through its counsel of

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record Robert P. Soran of Downey Brand, and Wong Family Investors, L.P., by and through its

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counsel of record John C. Lassner of the Law Office of John C. Lassner, stipulate and agree as

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follows:
1297891.1

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THIRD STIPULATION TO EXTEND TIME TO RESPOND TO COUNTER AND CROSS-CLAIMS; [PROPOSED] ORDER

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The deadline for Plaintiffs to respond to the Counter and Cross-Claims filed by Century

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Indemnity Company, as successor to CCI Insurance Company, as successor to Insurance

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Company of North America, as alleged insurer of The Estate of Ronald G. Armstrong, Deceased,

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pursuant to California Probate Code section 550 et seq., (“Century”), shall be extended from

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January 25, 2013, up to and including April 30, 2013. The extension provided for by this

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Stipulation may be terminated by any party to this Stipulation by service of written notice of

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termination served by hand delivery, email, or facsimile. If the extension provided for by this

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Stipulation is so terminated, the deadline for Plaintiffs to respond to the Counter and Cross-

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Claims filed by Century shall be 20 days after the date of delivery of the notice of termination.

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The parties hereto previously stipulated to two prior extensions from November 30, 2012 to

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December 28, 2012, and from December 28, 2012 to January 25, 2013. Good cause exists for the

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requested extension. Several parties to this action, including but not limited to the parties to this

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stipulation, are engaged in settlement discussions, have participated in a full day of mediation

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before Robert Kaplan of Judicate West, and have agreed to continue the mediation to a mutually

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acceptable date in the future. The parties are hopeful that the continued mediation will take place

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in late March or April 2013, and are working to coordinate and schedule this continued

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mediation. Based on the status of the parties settlement discussions and mediation, as well as

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other factors, the parties are meeting and conferring about the possibility of filing a joint motion

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seeking a further brief stay of the litigation. The requested extension would allow the parties to

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conserve their limited resources while these settlement discussions and mediation are ongoing.

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DATED: January 18, 2013

DOWNEY BRAND LLP

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By: /s/ Robert P. Soran
ROBERT P. SORAN
Attorneys for Plaintiff and Counterdefendant
BEL AIR MART, a California corporation

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1297891.1

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THIRD STIPULATION TO EXTEND TIME TO RESPOND TO COUNTER AND CROSS-CLAIMS; ORDER

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DATED: January 18, 2013

LAW OFFICE OF JOHN C. LASSNER

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By: /s/ John C. Lassner [as authorized on 01/18/13]
JOHN C. LASSNER
Attorneys for Plaintiff and Counterdefendant
WONG FAMILY INVESTORS, L.P.

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DATED: January 18, 2013

BASSI EDLIN HUIE & BLUM LLP

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By: /s/ Farheena Habib [as authorized on 01/18/13]
FARHEENA HABIB
Attorneys for CENTURY INDEMNITY
COMPANY, on behalf of Defendant and
Counterclaimant THE ESTATE OF RONALD G.
ARMSTRONG, DECEASED

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ORDER

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Pursuant to the joint stipulation of the parties, and good cause appearing, the request to

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extend the deadline for Plaintiffs to respond to the Counter and Cross-Claims filed by Century
Indemnity Company, as successor to CCI Insurance Company, as successor to Insurance
Company of North America, as alleged insurer of The Estate of Ronald G. Armstrong, Deceased,
pursuant to California Probate Code section 550 et seq., is GRANTED. The deadline for
Plaintiffs to respond to the Counter and Cross-Claims is hereby extended from January 25, 2013,
up to and including April 30, 2013. The extension provided for by this Stipulation may be
terminated by any party to this Stipulation by service of written notice of termination served by
hand delivery, email, or facsimile. If the extension provided for by this Stipulation is so
terminated, the deadline for Plaintiffs to respond to the Counter and Cross-Claims filed by
Century shall be 20 days after the date of delivery of the notice of termination.
Dated: January 22, 2013
_________________________________________
MORRISON C. ENGLAND, JR., CHIEF JUDGE
UNITED STATES DISTRICT COURT

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DEAC_Signature-END:

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1297891.1

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THIRD STIPULATION TO EXTEND TIME TO RESPOND TO COUNTER AND CROSS-CLAIMS; ORDER