St. Paul Reinsurance Company Limited London v. The Fort Miller Group, Inc. et al

Filing 156

ORDER GRANTING EXTENSION OF CERTIFICATION DEADLINE. Signed by Magistrate Judge Bernard Zimmerman on 9/25/2008. (bzsec, COURT STAFF) (Filed on 9/25/2008)

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SQUIRE , SANDERS & DEMPSEY L.L.P. SQUIRE SANDERS September 24, 2008 LEGAL COUNSEL WORLDWIDE One Maritime Plaza, Suite 300 San Francisco , CA 94111 Direct: +1.415.954.0383 Fax: +1.415.393.9887 dbalmat@ssd.com VIA ELECTRONIC FILING (AND NEXT-DAY HAND DELIVERY) Hon. Magistrate Judge Bernard Zimmerman United States District Court, N.D. California 450 Golden Gate Avenue 15th Floor, Courtroom G San Francisco, CA 94102 Re: Unionamerica Insurance Company Limited v. The Fort Miller Group , Inc. et al., N.D. Cal. Case No. C05-1912 BZ Dear Judge Zimmerman: Through their undersigned counsel, the parties hereby jointly request a two-week extension of the deadline for the parties to certify pursuant to the Court's Order Scheduling Jury Trial and Pretrial Matters that all discovery supplementation has been completed, from the current deadline of September 24, 2008 to October 8, 2008. Such an extension is necessary because the current deadline for such certification is today, September 24, and both sides believe that further supplementation will be necessary. The parties have been working to complete discovery and, as a result of the meet and confer process surrounding these efforts, and to avoid motions to compel supplementing various responses, have only very recently either agreed to provide certain supplemental responses or become aware of a potential need for additional supplementation. The parties are currently determining the precise extent to which additional supplementation may be necessary, and anticipate being able to complete whatever supplementation should ultimately prove necessary by October 8, 2008. 9/25/2008 For the foregoing reasons, the parties respectfully request that the certification deadline be ES DISTRICT T C extended from September 24, 2008 to October 8, 2008. TA Respectfully submitted, / Respectfully submitted, UNIT ED RT U O S GRAN TED 5a iel T. Balmat 3 SQUIRE, SANDERS & DEMPSEY, L.L.P. Attorneys for The Fort Miller Group, Inc., The Fort Miller Company, and Beeche Systems S LMAN BREITMAN LLP Attorneys for Unionamerica Insurance E Company RN Limited D RT H F IS T RIC T O C NcmAn CLEvFa.AND CoLUMBus HousTON Los ANGE Fs Mww NEw YoRK PALOALTo PHOENm SAN FRANCLsco . TALLAHASSEE TAMPA- TYsoNs CORNER WASHINGTON DC WEST PALM BEACH I CARACAS Rio DF. JANF7Ro. SANTO DOMINGO . SAO PAULO I BRAnsLAVA . BRUssELS BUDAPEST FRANKFURT KYrv LONDON . Moscow -PRAGUE WARsAw I BEUING HONG KONG . SHm4GRm TOKYO I ASsociATED OFRcEs: BUCHAREST BUENOS ARTS DUBLIN SAN'nAGO www.ssd.Com A C LI FO R^yk V Steens Judge B ernard Z immerm an R NIA NO

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