Rand v. American National Insurance Company
Filing
154
ORDER continuing motion to certify class to 4/8/11 (tf, COURT STAFF) (Filed on 10/18/2010)
Rand v. American National Insurance Company
Doc. 154
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WATERS KRAUS & PAUL INGRID M. EVANS (179094) ievans@waterskraus.com JENNIFER MCINTOSH (264903) jmcintosh@waterskraus.com 711 Van Ness Avenue, Suite 220 San Francisco, CA 94102 Telephone: (415/296-6060 or 800/226-9880 214/777-0470 (fax) BONNETT, FAIRBOURN, FRIEDMAN & BALINT P.C. ANDREW S. FRIEDMAN (Pro Hac Vice admission) afriedman@bffb.com KIMBERLY C. PAGE (Pro Hac Vice admission) kpage@bffb.com 2901 N. Central Avenue, Suite 1000 Phoenix, AZ 85012 Telephone: 602/274-1100 602/274-1199 (fax) Attorneys for Plaintiff and the Putative Class UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION DAPHNE P. RAND, by and through DEBRA J. DOLCH, as Conservator of the Person and Estate of DAPHNE P. RAND, Conservatee, on Behalf of Themselves and All Others Similarly Situated. Plaintiff, vs. AMERICAN NATIONAL INSURANCE COMPANY, a Texas corporation. Defendant. This stipulation is made between Plaintiff DEBRA J. DOLCH, as Special Administrator of the Estate of DAPHNE P. RAND ("Plaintiff") and Defendant American National Insurance Company ("ANICO" or "Defendant"), by and through their respective counsel of records, based on the following: 1
STIPULATION AND PROPOSED ORDER CONTINUING BRIEFING SCHEDULE
Dockets.Justia.com
Case No. CV 09 0639 SI
CLASS ACTION STIPULATION AND [PROPOSED] ORDER CONTINUING BRIEFING SCHEDULE Judge Susan Illston Action Filed: 02/12/09
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WHEREAS, Plaintiff agrees she will not amend the complaint or add parties between now and the time ANICO responds to her Motion for Class Certification, but reserves the right to so amend and/or intervene with a new or additional plaintiff based upon any challenges or objections by Defendant. Defendant reserves its rights to any and all defenses to such amendment or interventions, if any.
6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: October 13, 2010 BONNETT, FAIRBOURN, FRIEDMAN & BALINT P.C. /s/Andrew S. Friedman------By: ANDREW S. FRIEDMAN Attorneys for Plaintiff DEBRA J. DOLCH, as Special Administrator of the Estate of DAPHNE P. RAND 2
STIPULATION AND PROPOSED ORDER CONTINUING BRIEFING SCHEDULE
WHEREAS, the current schedule requires plaintiffs to submit their class certification motion and expert disclosures on November 4, 2010. The parties are still conducting discovery: Defendant has not yet completed document production; and depositions of additional witnesses will be scheduled after the final document production. The parties believe that the current scheduling order on class certification should be modified to allow for completion of discovery, resolution of any discovery disputes and any other matters, as follows: Current Dates Plaintiff's Motion for Class Certification and Designation of Class Cert Experts Defendant's Opposition to Motion for Class Certification and Expert Disclosures Plaintiff's Reply in Support of Motion for Class Certification Hearing on Motion for Class Certification November 4, 2010 Proposed Dates January 21, 2011
January 6, 2011
March 11, 2011
January 20, 2011
March 25, 2011
February 4, 2011
April 8, 2011
THEREFORE, it is hereby stipulated between the undersigned parties, through their counsel of record, that the briefing schedule for Plaintiff's Motion Class Certification briefing may be continued as set forth above, subject to approval by the Court.
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STIPULATION AND PROPOSED ORDER CONTINUING BRIEFING SCHEDULE
DATED: October 13, 2010
GREER, HERZ & ADAMS, LLP
By:
/s/Joseph R. Russo with permission JOSEPH R. RUSSO Attorneys for Defendant AMERICAN NATIONAL INSURANCE COMPANY
ATTESTATION OF SIGNATURE Pursuant to General Order No. 45, § X(b), I hereby attest under penalty of perjury that concurrence in the filing of the document has been obtained from all signatories. DATED: October 13, 2010 BONNETT, FAIRBOURN, FRIEDMAN & BALINT P.C.
/s/Andrew S. Friedman ANDREW S. FRIEDMAN
IT IS SO ORDERED. DATED: ____________________ By The Honorable Susan Illston District Court Judge
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