State Compensation Ins. Fund v. Lara et al

Filing 11

STIPULATION and ORDER signed by District Judge John A. Mendez on 9/10/20 ORDERING that the last date for the Parties to confer pursuant to Rule 26(f) and to submit a Joint Status Report shall be continued until two weeks following the filing of Defendants' Answer to the Complaint or to any amended Complaint. (Kaminski, H)

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NOAH GRAFF, Assistant Chief Counsel, (SBN# 192795)
[e-mail]
R. TIMOTHY O’CONNOR, Staff Counsel (SBN# 179631)
[e-mail]
JOHN B. DE LEON, Staff Counsel, (SBN# 261381)
[e-mail]
STATE COMPENSATION INSURANCE FUND
900 Corporate Center Drive, Suite 401
Monterey Park, California 91754
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
STATE COMPENSATION INSURANCE FUND,
A Public Enterprise Fund
MICHAEL J. STRUMWASSER (SBN 58413)
BRYCE A. GEE (SBN 222700)
JULIA MICHEL (SBN 331864)
STRUMWASSER & WOOCHER LLP
10940 Wilshire Boulevard, Suite 2000
Los Angeles, California 90024
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants
RICARDO LARA and THE CALIFORNIA
DEPARTMENT OF INSURANCE

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA

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STATE COMPENSATION INSURANCE
FUND, a Public Enterprise Fund,

CASE NO. 2:20-CV-01289-JAM-CKD
STIPULATION AND ORDER TO
CONTINUE RULE 26(F)
CONFERENCE AND JOINT STATUS
REPORT DEADLINES

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Plaintiff,
vs.

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RICARDO LARA in his capacity as
INSURANCE COMMISSIONER OF THE
STATE OF CALIFORNIA; and THE
CALIFORNIA DEPARTMENT OF
INSURANCE, an Agency of the State of
California,

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STATE
COMPENSATION
INSURANCE FUND
CORPORATE LEGAL

Defendants.
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CASE NO. 2:20-CV-01289-JAM-CKD

STIPULATION AND ORDER TO CONTINUE RULE 26(F) CONFERENCE AND
JOINT STATUS REPORT DEADLINES

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Plaintiff STATE COMPENSATION INSURANCE FUND (“Plaintiff” or “State Fund”),

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and Defendants RICARDO LARA in his capacity as INSURANCE COMMISSIONER OF THE

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STATE OF CALIFORNIA, and THE CALIFORNIA DEPARTMENT OF INSURANCE, an

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Agency of the State of California (“Defendants”)(collectively, the “Parties”), by and through their

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respective counsel of record, hereby respectfully apply to this Court for an Order continuing the

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date for the Parties to confer as required by Fed. R. Civ. P. 26(f) and to prepare and submit a joint

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status report as set forth below.
WHEREAS, on June 26, 2020, State Fund filed a Complaint for Declaratory and Injunctive

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Relief;

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WHEREAS, service was effectuated on July 20, 2020;

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WHEREAS, Defendants’ response to Complaint is currently due on October 6, 2020,

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pursuant to Parties Stipulation filed on August 31, 2020;

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WHEREAS, pursuant to the Order Requiring Service of Process and Joint Status Report,

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provided by the Court upon filing of the complaint, the sixty (60) day deadline to confer, prepare,

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and submit a Joint Status Report currently falls on September 18, 2020;

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WHEREAS, the Parties have met and conferred on Plaintiff’s Complaint and Defendants’

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intent to respond by way of a motion to dismiss Plaintiff’s Complaint, and the parties agreed that

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postponing the Rule 26(f) conference and the Joint Status Report until after a ruling on Defendants’

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motion and after the pleadings are set would permit a more meaningful Rule 26(f) conference and

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a more complete Joint Status Report;

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NOW, THEREFORE, IT IS HEREBY STIPULATED, between the Parties, subject to the

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Court’s approval, that: the last date for the Parties to confer pursuant to Rule 26(f) and to submit a

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Joint Status Report shall be continued until two weeks following the filing of Defendants’ Answer

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to the Complaint or to any amended Complaint.

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STATE
COMPENSATION
INSURANCE FUND
CORPORATE LEGAL

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CASE NO. 2:20-CV-01289-JAM-CKD

STIPULATION AND ORDER TO CONTINUE RULE 26(F) CONFERENCE AND
JOINT STATUS REPORT DEADLINES

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IT IS SO STIPULATED.
DATED: September 10, 2020

STRUMWASSER & WOOCHER LLP

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By: /s/Michael J. Strumwasser
Michael J. Strumwasser
Bryce Gee
Julia Michel

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Attorneys for Defendants
RICARDO LARA in his capacity as INSURANCE
COMMISSIONER OF THE STATE OF
CALIFORNIA; and THE CALIFORNIA
DEPARTMENT OF INSURANCE, an Agency of
the State of California

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DATED: September 10, 2020

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NOAH GRAFF
Assistant Chief Counsel

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By: /s/R. Timothy O’Connor
R. Timothy O’Connor
John B. de Leon
Attorneys for Plaintiff
STATE COMPENSATION INSURANCE FUND

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ORDER

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For good cause shown, the above Stipulation is adopted as follows:

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The last date for the Parties to confer pursuant to Rule 26(f) and to submit a Joint Status

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Report shall be continued until two weeks following the filing of Defendants’ Answer to the

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Complaint or to any amended Complaint.

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IT IS SO ORDERED.

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Dated: September 10, 2020
/s/ John A. Mendez
Hon. John A. Mendez, U.S. District Court Judge

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STATE
COMPENSATION
INSURANCE FUND
CORPORATE LEGAL

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CASE NO. 2:20-CV-01289-JAM-CKD

STIPULATION AND ORDER TO CONTINUE RULE 26(F) CONFERENCE AND
JOINT STATUS REPORT DEADLINES