Rand v. American National Insurance Company

Filing 174

ORDER Motion Hearing set for 7/8/2011 09:00 AM before Hon. Susan Illston. re 173 Stipulation. (tf, COURT STAFF) (Filed on 3/22/2011) Modified on 3/23/2011 (ys, COURT STAFF).

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Rand v. American National Insurance Company Doc. 174 1 2 3 4 5 6 7 8 9 10 11 12 13 THE EVANS LAW FIRM INGRID M. EVANS (179094) Ingrid@evanslaw.com One Embarcadero PO Box 2323 San Francisco, CA 94194126-2323 Telephone: 415/441-8669 or 888/503-8267 888/8917-4906 (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 14 NORTHERN DISTRICT OF CALIFORNIA 15 SAN FRANCISCO DIVISION 16 17 18 19 Plaintiff, 20 vs. 21 22 23 24 This stipulation is made between Plaintiff DEBRA J. DOLCH, as Special Administrator of 25 the Estate of DAPHNE P. RAND ("Plaintiff") and Defendant American National Insurance 26 Company ("ANICO" or "Defendant"), by and through their respective counsel of records, based 27 on the following: 28 1 STIPULATION AND PROPOSED ORDER CONTINUING BRIEFING SCHEDULE 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. Case No. CV 09 0639 SI CLASS ACTION STIPULATION AND [PROPOSED] ORDER CONTINUING BRIEFING SCHEDULE Judge Susan Illston Action Filed: 02/12/09 AMERICAN NATIONAL INSURANCE COMPANY, a Texas corporation. Defendant. Dockets.Justia.com 1 2 3 4 5 6 interventions, if any. 7 8 9 10 11 12 13 14 as follows: 15 16 17 18 19 20 21 22 23 24 25 26 27 28 2 STIPULATION AND PROPOSED ORDER CONTINUING BRIEFING SCHEDULE 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 WHEREAS, the current schedule requires plaintiffs to submit their class certification motion and expert disclosures on March 21, 2011. Currently the parties are actively involved in settlement negotiations and will continue with discovery if settlement terms are not reached. Based on the status of the negotiations, the parties believe that the current scheduling order on class certification should be modified to allow for settlement negotiations to proceed or, alternatively, completion of discovery, resolution of any discovery disputes and any other matters, 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 [Proposed] Hearing on Motion for Class Certification March 21, 2011 Proposed Dates April 21, 2011 May 11, 2011 June 11, 2011 May 25, 2011 June 25, 2011 June 8, 2011 July 8, 2011 /// /// 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 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. DATED: March 21, 2011 THE EVANS LAW FIRM By: /s/ INGRID M. EVANS Attorneys for Plaintiff DEBRA J. DOLCH, as Special Administrator of the Estate of DAPHNE P. RAND DATED: March 21, 2011 GREER, HERZ & ADAMS, LLP By: /s/ 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. THE EVANS LAW FIRM DATED: March 21, 2011 By: /s/ INGRID M. EVANS IT IS SO ORDERED. DATED: ____________________ 3/22/11 By The Honorable Susan Illston District Court Judge 3 STIPULATION AND PROPOSED ORDER CONTINUING BRIEFING SCHEDULE

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