Rand v. American National Insurance Company

Filing 159

ORDER extending ENE deadline (tf, COURT STAFF) (Filed on 11/18/2010)

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Rand v. American National Insurance Company Doc. 159 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 WATERS KRAUS & PAUL LLP INGRID M. EVANS (179094) ievans@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, PC ANDREW S. FRIEDMAN (Pro Hac Vice) afriedman@bffb.com KIMBERLY C. PAGE (Pro Hac Pending) kpage@bffb.com 2901 North Central Avenue, Suite 1000 Phoenix, AZ 85012 Telephone: 602-274-1100 Attorneys for Plaintiffs UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION DAPHNE P. RAND, by and through DEBRA L. DOLCHE, as Conservator of the Person and Estate of DAPHNE P. RAND, Conservatee, on Behalf of Themselves and All Others Similarly Situated, ) ) ) ) ) ) Plaintiff, ) ) v. ) ) ) AMERICAN NATIONAL INSURANCE ) COMPANY, a Texas corporation, ) ) Defendant. ______________________________________ ) Case No. CV 09-0639-SI STIPULATION AND [PROPOSED] ORDER CONTINUING ENE COMPLETION DATE (Assigned to the Honorable Susan Illston) 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: -1STIPULATION AND [PROPOSED] ORDER CONTINUING ENE COMPLETION DATE Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 WHEREAS, the completion for the Early Neutral Evaluation is currently scheduled for November 30, 2010. WHEREAS, the parties agree that the completion of Early Neutral Evaluation should be extended until after Plaintiff files her motion for class certification on January 21, 2011. THEREFORE, it is hereby stipulated between the undersigned parties, through their counsel of record that, with the Court's permission, the deadline for completion of Early Neutral Evaluation be continued to February 28, 2011. DATED: November 16, 2010 WATERS KRAUS & PAUL By: /s/ Ingrid M. Evans Attorneys for Plaintiff DAPHNE P. RAND, by and through DEBRA J. DOLCH, as Conservator of the Person and Estate of DAPHNE P. RAND, Conservatee DATED: November 16, 2010 GREER, HERZ & ADAMS, LLP By: /s/ JOSEPH R. RUSSO Attorneys for Defendant AMERICAN NATIONAL INSURANCE COMPANY ATTESTATION OF SIGNATURE (N.D. Cal. General Order 45) 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 the signatories. DATED: November 16, 2010 WATERS KRAUS & PAUL By: /s/ Ingrid M. Evans -2STIPULATION AND [PROPOSED] ORDER CONTINUING ENE COMPLETION DATE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DATED: ____________________ IT IS SO ORDERED. ORDER By The Honorable Susan Illston District Court Judge -3STIPULATION AND [PROPOSED] ORDER CONTINUING ENE COMPLETION DATE 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CERTIFICATE OF SERVICE I hereby certify that on November 16, 2010, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the email addresses denoted on the Electronic Mail notice list, and I hereby certify that I have mailed the foregoing document or paper via the United States Postal Service to the non-CM/ECF participants indicated on the Manual Notice list. I certify under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on November 16, 2010. By: /s/ Rochelle Redmayne Rochelle Redmayne WATERS KRAUS & PAUL LLP 711 Van Ness Avenue, Suite 220 San Francisco, CA 94102 Telephone: 415/296-6060 or 800/226-9880 214/777-0470 (fax) rredmayne@waterskraus.com -1CERTIFICATE OF SERVICE

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