Van Curen v. Federal Crop Insurance Corporation et al

Filing 13

STIPULATION AND ORDER POSTPONING ALL CASE MANAGEMENT DEADLINES pending the decision on Defendant's Motion to Dismiss re doc 12 filed by Risk Management Agency, Federal Crop Insurance Corporation. Signed by Judge Vaughn R Walker on 11/9/2009. (cgk, COURT STAFF) (Filed on 11/10/2009)

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JOSEPH P. RUSSONIELLO (SBN 44332) United States Attorney JOANN M. SWANSON (SBN 88143) Chief, Civil Division JONATHAN U. LEE (SBN 148792) Assistant United States Attorney 450 Golden Gate Avenue, Ninth Floor San Francisco, California 94102 Telephone: [phone] Facsimile: [phone] Email: [e-mail] Attorneys for FEDERAL CROP INSURANCE COMPANY RISK MANAGEMENT AGENCY MERLE C. MEYERS, ESQ. (SBN 66849) D. CLARKE SUGAR (SBN 251681) MEYERS LAW GROUP, PC 44 Montgomery Street, Suite 1010 San Francisco, CA 94104 Telephone: [phone] Facsimile: [phone] ATTORNEYS FOR JOHN VAN CUREN, AS TRUSTEE OF THE CHAPTER 11 ESTATE OF MICHAEL HAT, A/K/A MICHAEL HAT FARMING COMPANY UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION JOHN VAN CUREN, AS TRUSTEE OF THE CHAPTER 11 ESTATE OF MICHAEL HAT, A/K/A MICHAEL HAT FARMING COMPANY, Plaintiff, v. FEDERAL CROP INSURANCE COMPANY, RISK MANAGEMENT AGENCY, Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) No. C 09-3509 VRW STIPULATION AND [PROPOSED] ORDER TO POSTPONE ALL CASE MANAGEMENT DEADLINES PENDING THE DECISION ON DEFENDANTS' MOTION TO DISMISS

STIPULATION AND PROPOSED ORDER C a s e s C 09-3509 VRW

1 THE PARTIES HEREBY STIPULATE AND AGREE AS FOLLOWS: 2 1. 3 the parties to meet and confer regarding Rule 26 initial disclosures, early 4 settlement, ADR selection and a discovery plan; the filing of a stipulation 5 selecting an ADR method; service of Rule 26 initial disclosures, and filing of a 6 report regarding discovery, should be postponed until after the Court decides 7 defendant's motion to dismiss for failure to state a claim and for lack of 8 jurisdiction and in the alternative to dismiss for improper venue. 9 2. 10 3. 11 defendant's motion, set a new date and time for the initial case management 12 conference, with dates for exchange of initial disclosures, discussion of early 13 settlement, ADR selection and discovery plan derived from the date for the initial 14 case management conference. 15 16 SO STIPULATED. 17 18 19 20 21 22 23 24 25 26 27 28
STIPULATION AND PROPOSED ORDER C a s e s C 09-3509 VRW

The pending case management deadlines in this matter, including the deadline for

The motion is scheduled for hearing on January 7, 2010. The parties request that the Court, if appropriate following the ruling on

DATED: November 3, 2009

MEYERS LAW GROUP, PC /s/ MERLE C. MEYERS, ESQ. Attorney for Plaintiff JOHN VAN CUREN

DATED: November 9, 2009

JOSEPH P. RUSSONIELLO United States Attorney /s/ JONATHAN U. LEE Assistant United States Attorney Attorneys for Defendants FEDERAL CROP INSURANCE COMPANY, RISK MANAGEMENT AGENCY

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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HON. VAUGHN R. WALKER United States District Judge D

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11/9/2009 DATED: __________________

S DISTRICT TE C A ________T ________________________ _

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STIPULATION AND PROPOSED ORDER C a s e s C 09-3509 VRW

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