Levin Enterprises Inc. v. Maryland Casualty Company et al

Filing 20

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 4/22/2015: The 4/28/2015 Settlement Conference is CONTINUED to 8/14/2015 at 09:30 AM in Courtroom 24 (CKD) before Magistrate Judge Carolyn K. Delaney. Settlement statements due no later than seven (7) days prior. (Owen, K)

1 HANSON BRIDGETT LLP
LINDA E. KLAMM, SBN 71506
2 [e-mail]
MILES C. HOLDEN, SBN 263342
3 [e-mail]
HANI GANJI, SBN 272925
4 [e-mail]
425 Market Street, 26th Floor
5 San Francisco, California 94105
Telephone:
[phone]
6 Facsimile:
[phone]
7 Attorneys for Plaintiff
LEVIN ENTERPRISES, INC.
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION

11 LEVIN ENTERPRISES, INC.,

CASE NO. 2:14-CV-01479-MCE-AC

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STIPULATION AND [PROPOSED]
ORDER TO RESCHEDULE
SETTLEMENT CONFERENCE

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Plaintiff,
v.

14 MARYLAND CASUALTY COMPANY as
successor in interest to Maine Bonding &
15 Casualty Company; MAINE BONDING &
CASUALTY COMPANY; and GRANITE
16 STATE INSURANCE COMPANY,
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Judge: Hon. Carolyn K. Delaney
Complaint filed: June 20, 2014

Defendants.

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This Stipulation is entered into by and between Plaintiff, LEVIN ENTERPRISES, INC.

20 ("LEVIN") and Defendants ZURICH AMERICAN INSURANCE COMPANY (“Zurich
21 American”) as successor in interest to MAINE BONDING & CASUALTY COMPANY, which
22 Zurich American contends was erroneously sued as “MARYLAND CASUALTY COMPANY as
23 successor in interest to Maine Bonding & Casualty Company; MAINE BONDING &
24 CASUALTY COMPANY”; and GRANITE STATE INSURANCE COMPANY ("GRANITE").
25 RECITALS
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1.

On April 2, 2015, the parties mediated the matter before Mr. Craig Meredith of

27 JAMS. While the parties were not able to resolve the case at that time, they agreed to a further
28 exchange of information and documents to assist in a good faith attempt to settlement the matter.
11109373.1

STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE SETTLEMENT CONFERENCE

1

2.

The parties, however, are still in the process of exchanging information and

2 documents and will not complete their review before the April 28, 2015 Settlement Conference.
3 Thus, the parties cannot engage in meaningful settlement discussions at the currently scheduled
4 April 28, 2015 Settlement Conference.
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3.

Based on LEVIN’s counsel’s discussion with Mr. Kyle Owen, Judge Delaney’s

6 Courtroom Deputy, the Settlement Conference may be rescheduled to August 14, 2015. This date
7 will give the parties sufficient time to complete their exchange and review of documents and
8 engage in further settlement discussions.
9 IT IS HEREBY STIPULATED AND AGREED:
10

5.

Pursuant to Local Rules 143 and 144(a), the Settlement Conference currently

11 scheduled for April 28, 2015 will be rescheduled to August 14, 2015.
12 DATED: April 21, 2015

HANSON BRIDGETT LLP

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By:

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/s/ Hani Ganji
LINDA E. KLAMM
MILES C. HOLDEN
HANI GANJI
Attorneys for
LEVIN ENTERPRISES, INC

17 DATED: April 21, 2015

SELMAN BREITMAN LLP

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15

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By:

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/s/ Mark E. Inbody
LINDA WENDELL HSU
MARK E. INBODY
Attorneys for
ZURICH AMERICAN INSURANCE
COMPANY

22 DATED: April 21, 2015

LYNBERG & WATKINS

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By:

/s/ Jerome P. Doctors
R. JEFF CARLISLE
JEROME P. DOCTORS
RYAN C. BYKERK
Attorneys for
GRANITE STATE INSURANCE COMPANY

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11109373.1

-2STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE SETTLEMENT CONFERENCE

1 IT IS SO ORDERED.
2
3 Dated: April 22, 2015
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_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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11109373.1

-3STIPULATION AND [PROPOSED] ORDER TO RESCHEDULE SETTLEMENT CONFERENCE