United States of America v. Gonzales & Gonzales Bonds and Insurance Agency, Inc. et al

Filing 122

STIPULATION AND ORDER CHANGING TWO DATES IN SCHEDULING ORDER FILED ON 5/1/12 re 121 STIPULATION WITH PROPOSED ORDER re 120 Case Management Conference - Further, Set Deadlines/Hearings,, Stipulation to Change Two Dates in Scheduling Order filed by United States of America. Signed by Judge Edward M. Chen on 5/3/12. (bpf, COURT STAFF) (Filed on 5/3/2012)

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UNITED STATES DEPARTMENT OF JUSTICE
Ruth A. Harvey, Assistant Director
Frances M. McLaughlin
E. Kathleen Shahan
John J. Siemietkowski
Trial Attorneys
Civil Division, Commercial Litigation Branch
P.O. Box 875, Ben Franklin Station
Washington, DC 20044-0875
Tel: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION

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) Case No. C 09-04029 EMC
)
)
Plaintiff,
)
vs.
) STIPULATION TO CHANGE TWO DATES
GONZALES & GONZALES BONDS AND ) IN SCHEDULING ORDER ; ORDER
)
INSURANCE AGENCY, INC. and
AMERICAN SURETY COMPANY, INC., )
)
)
Defendants.
)
)
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GONZALES & GONZALES BONDS AND )
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INSURANCE AGENCY, INC. and
AMERICAN SURETY COMPANY, INC. )
)
)
Counterclaimants,
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vs.
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UNITED STATES DEPARTMENT OF
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HOMELAND SECURITY, JANET
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NAPOLITANO, in her capacity as
)
SECRETARY OF UNITED STATES
)
DEPARTMENT OF HOMELAND
)
SECURITY
)
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Counterdefendants.
)
UNITED STATES OF AMERICA,

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Stipulation to Change Two Dates
in Scheduling Order

04-CV-4029 EMC
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Pursuant to Civil L.R. 6-1(b), 6-2, and 7-12, Plaintiff United States of America,

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Counterdefendants United States Department of Homeland Security and Janet Napolitano, in her

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capacity as Secretary of United States Department of Homeland Security (collectively “United

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States”), on the one hand, and Defendants/Counterclaimants Gonzales & Gonzales Bonds and

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Insurance Agency, Inc. and American Surety Company, Inc. (“G&G/ASC”), on the other hand,

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by and through their respective counsel of record, bring this administrative motion by stipulation,

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and stipulate and agree as follows:

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1.

The Court issued a scheduling order on May 1, 2012, dkt. 120.

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2.

After coordinating their respective schedules, the parties agree that the June 8

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deadline in dkt. 120 should change to June 15, and that the June 15 deadline should change to

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June 22. The parties agree that all other deadlines should remain in place.

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3.

This is the first proposed time modification to dkt. 120.

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4.

In order for the parties to better identify and exchange documents proposed for the

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Administrative Record, the parties respectfully request that the Court change the June 8 deadline

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in dkt. 120 to June 15, and change the June 15 deadline to June 22.

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IT IS SO STIPULATED.

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Dated: May 3, 2012

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STUART F. DELERY
Acting Assistant Attorney General
MELINDA HAAG
United States Attorney

ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP

/s/ John J. Siemietkowski__________
J. CHRISTOPHER KOHN
RUTH A. HARVEY
E. KATHLEEN SHAHAN
(D.C. Bar No. 267872)
JOHN J. SIEMIETKOWSKI
(PA Bar. No. 50346)
FRANCES M. MCLAUGHLIN
(FL Bar No. 0256640)
Trial Attorneys
Civil Division

/s/ Gary A. Nye_______
GARY A. NYE
DAVID R. GINSBURG
Attorneys for Defendants/Counterclaimants
GONZALES & GONZALES BONDS AND
INSURANCE AGENCY, INC. and AMERICAN
SURETY COMPANY, INC.

Stipulation to Change Two Dates
in Scheduling Order

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04-CV-4029 EMC

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Attorneys for the United States of
America

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UNIT
ED

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Dated:

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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RDERE
S SO O
IT I
__________________________

May 3, 2012

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S DISTRICT
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R NIA

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EDWARD M. CHEN
United States District Judge
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M. Che
Edward
Judge

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Stipulation to Change Two Dates
in Scheduling Order

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FO

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LI

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Commercial Litigation Branch
P.O. Box 875, Ben Franklin Station
Washington, DC 20044-0875
Tel: [phone]
Fax: [phone]
[e-mail]

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04-CV-4029 EMC

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