Scottsdale Insurance Company v. Syngen Inc et al

Filing 18

STIPULATION and ORDER signed by Judge John A. Mendez on 8/14/15. Plaintiff's deadline to file and serve its opposition to the Motion to Dismiss and stay is extended to 10/7/15. Defendant's reply brief due by 10/14/15. The hearing on the 15 Motion to Dismiss is reset for 10/21/15 at 09:30 AM in Courtroom 6 (JAM) before Judge John A. Mendez. (Manzer, C) Modified on 8/14/2015 (Manzer, C). Modified on 8/14/2015 (Vine, H).

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KAUFMAN DOLOWICH & VOLUCK, LLP
LOUIS H. CASTORIA, ESQ. (SBN 95768)
SHEILA M. PHAM, ESQ. (SBN 293673)
425 California Street, Suite 2100
San Francisco, California 94104
Telephone: [phone]
Facsimile: [phone]
BAILEY CAVALIERI, LLC
SABRINA HAURIN, ESQ.
KEITH LITTLE, ESQ.
10 W. Broad Street, Suite 2100
Columbus, Ohio 43215-3422
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
SCOTTSDALE INSURANCE COMPANY

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FARELLA BRAUN + MARTEL, LLP
MARY E. MCCUTCHEON (SBN 99939)
TYLER C. GERKING (SBN 222088)
235 Montgomery Street
San Francisco, California 94104
Telephone: [phone]
Attorneys for Defendants SYNGEN, INC., PHILIP
COELHO, PRINCE EMMANLUEL, and
TERRENCE WOLF

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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA
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SCOTTSDALE INSURANCE COMPANY, ) Case No.: 2:15-CV-00142-JAM-DAD
an Ohio corporation,
)
)
Plaintiff,
)
) JOINT STIPULATION TO EXTEND TIME
v.
) TO RESPOND; ORDER
)
)
SYNGEN, INC., a California corporation,
)
PHILIP COELHO, an individual, PRINCE
)
EMMANLUEL, an individual, and
)
TERRENCE WOLF, an individual.
)
)
Defendants.
)
)

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-1JOINT STIPULATION TO EXTEND TIME TO RESPOND AND [PROPOSED] ORDER

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All parties herein, Plaintiff SCOTTSDALE INSURANCE COMPANY (“Plaintiff”) and

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Defendants SYNGEN, INC., PHILIP COELHO, PRINCE EMMANUEL, and TERRENCE WOLF

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(“Defendants”), collectively referred to as the “Parties,” have reached a joint stipulation regarding

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Plaintiff’s deadline to file and serve its opposition to Defendants’ Motion to Dismiss.

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RECITALS

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WHEREAS, Defendants filed a Motion to Dismiss, which is scheduled to be heard on

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September 2, 2015 at 9:30 a.m. in Department 6;
WHEREAS, Plaintiff’s deadline to file and serve its opposition to Defendants’ Motion to
Dismiss is currently August 19, 2015;
WHEREAS, the Parties agree to extend Plaintiff’s deadline to file and serve its opposition to
Defendants’ Motion to Dismiss until Monday, October 5, 2015;
WHEREAS, no extensions have already been obtained by any party as to Defendants’ Motion
to Dismiss;
WHEREAS, the Parties jointly request that the Court set a new hearing date for Defendants’

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Motion to Dismiss, currently scheduled for September 2, 2015 at 9:30 a.m. in Department 6, on or

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after October 12, 2015, as is convenient to the Court.

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[Stipulation follows on next page]

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-2JOINT STIPULATION TO EXTEND TIME TO RESPOND AND [PROPOSED] ORDER

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STIPULATION
IT IS HEREBY STIPULATED by and between the Parties hereto through their respective
attorneys of record as follows:
1.

Plaintiff’s deadline to file and serve its opposition to Defendants’ Motion to Dismiss is

extended from August 19, 2015 until October 5, 2015.
2.

The Parties jointly request that the Court set a new hearing date for Defendants’

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Motion to Dismiss, currently scheduled for September 2, 2015 at 9:30 a.m. in Department 6, on or

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after October 12, 2015, as is convenient to the Court.

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IT IS SO STIPULATED.

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DATED: _________________

KAUFMAN DOLOWICH & VOLUCK, LLP

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/s/ Louis H. Castoria
LOUIS H. CASTORIA, ESQ.
SHEILA M. PHAM, ESQ.
Attorneys for Plaintiff
SCOTTSDALE INSURANCE COMPANY

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DATED: August 13, 2015

BAILEY CAVALIERI, LLC

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/s/ Sabrina Haurin
SABRINA HAURIN, ESQ.
KEITH LITTLE, ESQ.
Attorneys for Plaintiff
SCOTTSDALE INSURANCE COMPANY

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DATED: August 13, 2015

FARELLA BRAUN + MARTEL, LLP

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/s/ Tyler C. Gerking
MARY E. MCCUTCHEON
TYLER C. GERKING
Attorneys for Defendants SYNGEN, INC., PHILIP
COELHO, PRINCE EMMANLUEL, and TERRENCE
WOLF
-3JOINT STIPULATION TO EXTEND TIME TO RESPOND AND [PROPOSED] ORDER

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ORDER
Having considered the foregoing Joint Stipulation of all Parties, and good cause appearing, IT
IS HEREBY ORDERED:
1. Plaintiff’s deadline to file and serve its opposition to Defendants’ Motion to Dismiss is
extended from August 19, 2015 until October 7, 2015;
2. Defendant’s reply brief shall be filed on or before October 14, 2015;
3. The Court resets the hearing on Defendants’ Motion to Dismiss, currently scheduled for
September 2, 2015 at 9:30 a.m. in Courtroom 6, to October 21, 2015, at 9:30 a.m. in Courtroom #6.

IT IS SO ORDERED.

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DATED: 8/14/2015
/s/ John A. Mendez________
Honorable John A. Mendez
U. S. District Court Judge

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-4JOINT STIPULATION TO EXTEND TIME TO RESPOND AND [PROPOSED] ORDER