Rand v. American National Insurance Company

Filing 176

ORDER vacating motion hearing & setting Further Case Management Conference set for 5/20/2011 03:00 PM. (tf, COURT STAFF) (Filed on 4/4/2011)

Rand v. American National Insurance Company

Doc. 176

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THE EVANS LAW FIRM INGRID M. EVANS (179094) [e-mail] One Embarcadero PO Box 2323 San Francisco, CA 94194126-2323 Telephone: [phone] or 888/503-8267 888/8917-4906 (fax) BONNETT, FAIRBOURN, FRIEDMAN & BALINT P.C. ANDREW S. FRIEDMAN (Pro Hac Vice admission) [e-mail] KIMBERLY C. PAGE (Pro Hac Vice admission) [e-mail] 2901 N. Central Avenue, Suite 1000 Phoenix, AZ 85012 Telephone: [phone] (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 Status Report and Stipulation To Vacate Scheduling Orders is submitted jointly by 25 Plaintiff DEBRA J. DOLCH, as Special Administrator of the Estate of DAPHNE P. RAND 26 ("Plaintiff") and Defendant American National Insurance Company ("ANICO" or "Defendant"), 27 by and through their respective counsel of records. The parties have reached agreement on 28 1
STATUS REPORT AND STIPULATION TO VACATE SCHEDULING ORDER

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 STATUS REPORT AND STIPULATION AND [PROPOSED] ORDER TO VACATE SCHEDULING ORDER Judge Susan Illston Action Filed: 02/12/09

AMERICAN NATIONAL INSURANCE COMPANY, a Texas corporation. Defendant.

Dockets.Justia.com

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several material economic terms of a proposed class settlement. The parties have begun the process of negotiating and preparing a formal settlement agreement. The parties contemplate that a settlement agreement will be finalized and submitted for preliminary approval by the Court within the forthcoming 45 days. In light of the parties' progress towards settlement and to avoid burdening the Court with additional requests to modify the existing pretrial schedule, the parties respectfully request the Court to vacate the following dates subject to a request for re-instatement by either party or reinstatement by the Court:

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 April 21, 2011

June 11, 2011

June 25, 2011

July 8, 2011

DATED: April 1, 2011 19 20 21 22 23 24 25 26 27 28 DATED: April 1, 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

GREER, HERZ & ADAMS, LLP

By:

/s/ JOSEPH R. RUSSO Attorneys for Defendant AMERICAN NATIONAL INSURANCE COMPANY 2

STATUS REPORT AND STIPULATION TO VACATE SCHEDULING ORDER

1 2 3 4 5 DATED: April 1, 2011 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 IT IS SO ORDERED.

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

By:

/s/ INGRID M. EVANS

4/1/11 DATED: ____________________ By The Honorable Susan Illston District Court Judge

Further Case Management Conference set on 5/20/11 @ 3 p.m. A joint statement shall be filed one week prior to the conference.

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STATUS REPORT AND STIPULATION TO VACATE SCHEDULING ORDER