State National Ins. Co. v. Collins Pine Company et al

Filing 67

STIPULATION and ORDER signed by Judge William B. Shubb on 5/4/2011 ORDERING hearing on 52 Defendants Motion to Dismiss CONTINUED to 7/18/2011 at 02:00 PM in Courtroom 5 (WBS) before Judge William B. Shubb.(Reader, L)

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MICHAEL W. JONES (State Bar No. 136872)
CHRISTINE E. JACOB (State Bar No. 216679)
JULIA M. REEVES (State Bar No. 241198)
HANSEN, KOHLS, JONES, SOMMER & JACOB, LLP
1520 EUREKA ROAD, SUITE 100
ROSEVILLE, CA 95661
TELEPHONE: [phone]
FACSIMILE: [phone]

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Attorneys for Defendants MANUEL MENDOZA
and GLORIA MENDOZA

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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STATE NATIONAL INSURANCE
COMPANY, a Texas corporation,

Case No. 2:10-CV-03093-WBS-KJN

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Plaintiff,

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vs.

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COLLINS PINE COMPANY, an Oregon
corporation; D & H TRANSPORTATION,
INC., a California corporation; MANUEL
MENDOZA, an individual; GLORIA
MENDOZA, an individual; PRAETORIAN
INSURANCE COMPANY, a Pennsylvania
corporation, and DOES 1 through 50,
inclusive,

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Defendants.
____________________________________/

STIPULATION TO CONTINUE
HEARING OF DEFENDANTS/CROSSDEFENDANTS MANUEL MENDOZA’S
AND GLORIA MENDOZA’S MOTION
TO DISMISS COUNTER-CLAIM AND
CROSS-CLAIM OF PRAETORIAN
INSURANCE COMPANY; [PROPOSED]
ORDER

Date: July 18, 2011
Time: 2:00 p.m.
Courtroom: 5
Honorable William B. Shubb
Complaint Filed: November 16, 2010

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PRAETORIAN INSURANCE COMPANY,

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Counter and Cross Claimant,

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vs.

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STATE NATIONAL INSURANCE
COMPANY; COLLINS PINE COMPANY;
D&H TRANSPORTATION, INC.; D&H
TRANSPORT, INC.; MANUEL MENDOZA;
GLORIA MENDOZA; and DOES 1 to 50,

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Counter and Cross Defendants.
____________________________________/

[164166]

-1Stip to Continue Hearing on Mendozas’ Mtn to Dismiss Counter-Claim/Cross-Claim of Praetorian

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IT IS HEREBY STIPULATED by and between Defendants/Cross-Defendants MANUEL

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MENDOZA and GLORIA MENDOZA and Defendant/Cross-Claimant PRAETORIAN

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INSURANCE COMPANY, and their respective counsel of record that pursuant to Local Rule

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230(f) the parties request a continuance of Defendants/Cross-Defendants Manuel Mendoza's and

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Gloria Mendoza's Motion to Dismiss Counter-Claim and Cross-Claim of Praetorian Insurance

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Company from May 16, 2011 to July 18, 2011 at 2:00 P.M. Good cause exists for this

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continuance as Defendants/Cross-Defendants MANUEL MENDOZA and GLORIA MENDOZA

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and Defendant/Cross-Claimant PRAETORIAN INSURANCE COMPANY are diligently

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attempting to negotiate a settlement between them, and it would be an efficient use of both the

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parties’ and the Court’s resources to avoid a potentially unnecessary hearing.

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DATED: May 3, 2011

HANSEN, KOHLS, JONES, SOMMER
& JACOB, LLP

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By _/s/ CHRISTINE E. JACOB
CHRISTINE E. JACOB
JULIA M. REEVES
Attorneys for Defendants/Cross-Defendants
MANUEL MENDOZA
and GLORIA MENDOZA

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DATED: May 3, 2011

DIEPENBROCK & COTTER LLP

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By /s/ JOHN P. COTTER
JOHN P. COTTER
Attorneys for Defendant/Cross-Claimant
PRAETORIAN INSURANCE COMPANY

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[164166]

-2Stip to Continue Hearing on Mendozas’ Mtn to Dismiss Counter-Claim/Cross-Claim of Praetorian

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ORDER

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IT IS SO ORDERED.

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DATED: May 4, 2011

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[164166]

-3Stip to Continue Hearing on Mendozas’ Mtn to Dismiss Counter-Claim/Cross-Claim of Praetorian