Crown Paper Liquidating Trust, v. American International Group, Inc. et al

Filing 105

ORDER APPROVING STIPULATION TO VACATE STATUS HEARING AND DEADLINES IN SCHEDULING ORDER. The following dates and deadlines are vacated: the November 7, 2008 status conference, the discovery cutoffs and deadlines to designate experts, the March 17, 200 9 deadline to file dispositive motions, the May 5, 2009 pretrial conference, and the May 18, 2009 trial. The parties are ordered to file a joint status statement no later than December 19, 2008, if the matter remains pending as of that date. Signed by Judge Maxine M. Chesney on October 29, 2008. (mmclc1, COURT STAFF) (Filed on 10/29/2008)

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BEUS GILBERT PLLC
ATTORNEYS AT LAW

4800 NORTH SCOTTSDALE ROAD SUITE 6000 SCOTTSDALE, ARIZONA 85251 TELEPHONE [phone]

Leo R. Beus/Ariz. Bar No. 002687 (pro hac vice pending) ­ [e-mail] Timothy J. Paris/Calif. Bar No. 90094 ­ [e-mail] Attorneys for Plaintiff

7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NORTHERN CALIFORNIA 9 Crown Paper Liquidating Trust, 10 Plaintiff, 11 v. 12 13 14 15 16 17 18 19 20 21 22 23 24 25
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Case No. 3:07-cv-02308-MMC JOINT STATUS REPORT AND STIPULATION TO VACATE STATUS HEARING AND DEADLINES IN SCHEDULING ORDER and [PROPOSED] ORDER THEREON Hearing date: Time: Judge: Courtroom: November 7, 2008 10:30 a.m. Maxine M. Chesney 17C, Nineteenth Floor

American International Group, Inc. d/b/a AIG, a Delaware corporation; National Union Fire Insurance Company of Pittsburgh, Pa., a Pennsylvania corporation; AIG Domestic Claims, Inc. f/k/a AIG Technical Services Inc., a Delaware corporation; Marsh USA Risk & Insurance Services Inc. d/b/a Marsh USA Inc., a Delaware corporation; Marsh & McLennan Companies, Inc, a Delaware corporation; Marsh Ltd., a United Kingdom corporation; Finpro, a division of Marsh Ltd.; Richard E Cowan, and Does One through 50, Defendants.

JOINT STATUS REPORT Plaintiff Crown Paper Liquidating Trust ("Crown") and Defendants American International Group, Inc., National Union Fire Insurance Company of Pittsburgh, Pa., and AIG Domestic Claims,

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Inc. (collectively with Crown, the "Parties") hereby submit the following status report, pursuant to this Court's August 28, 2008 Order: The Parties have executed their settlement agreement. On October 22, 2008, Crown

submitted the settlement agreement to Bankruptcy Judge Newsome of the United States Bankruptcy Court for the Northern District of California for approval. Crown expects that the settlement agreement will be approved as a matter of course shortly after the period for notice of objections expires on November 12, 2008. At such time, the Parties will jointly move this Court to dismiss the above-captioned case with prejudice. Accordingly, the Parties have entered into the below

stipulation to vacate the deadlines and status hearing set in this Court's October 29, 2007, scheduling order, as modified by this Court's orders on May 8, June 5, and August 28, 2008. STIPULATION

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The Parties hereby stipulate and agree, subject to this Court's approval, that each of

the discovery deadlines set forth in this Court's October 29, 2007, scheduling order, as modified by this Court's May 8, June 5, and August 28, 2008 orders, should be vacated. Hence, the parties request that this Court enter an order amending its scheduling order and vacating all of the following deadlines: the November 7, 2008, status conference; the December 5, 2008, non-expert discovery cutoff; the December 23, 2008, deadline for designation of experts; the January 16, 2009, deadline for designation of rebuttal experts; the February 16, 2009, expert discovery cutoff; the March 17, 2009, deadline for dispositive motions; the May 5, 2009, pre-trial conference; and the May 18, 2009, trial date.

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Further, the Parties jointly request that, in the event this Court denies their request to

vacate the November 7, 2008, status hearing, they be permitted to attend that hearing telephonically. 23 24 25
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IT IS HEREBY STIPULATED. DATED: October 28, 2008 QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP By: s/ Thad A. Davis Thad A. Davis Amanda Linn Attorneys for American International Group, Inc., National Union Fire Insurance Company of Pittsburgh, Pa., and AIG Domestic Claims, Inc.

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BEUS GILBERT PLLC By: s/ Leo R. Beus Leo R. Beus Timothy J. Paris Attorneys for Crown Paper Liquidating Trust

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[PROPOSED] ORDER Good cause appearing, IT IS HEREBY ORDERED that this Court's October 29, 2007 scheduling order, as modified by its May 8, June 5, and August 28, 2008, orders, are hereby amended vacating all of the following deadlines: the November 7, 2008, status conference; the December 5, 2008, non-expert discovery cutoff; the December 23, 2008, deadline for designation of experts; the January 16, 2009, deadline for designation of rebuttal experts; the February 16, 2009, expert discovery cutoff; the March 17, 2009, deadline for dispositive motions; the May 5, 2009, pre-trial conference; and the May 18, 2009, trial date. FURTHER, the parties are ORDERED to file a joint status statement no later than December 19, 2008, if the matter remains pending as of that date. DATED: October 29, 2008

Hon. Maxine M. Chesney United States District Judge

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