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

Filing 265

STIPULATION AND ORDER re 264 MODIFYING BRIEFING SCHEDULE SET FORTH IN THE CIVIL MINUTES OF OCTOBER 1, 2015 filed by Gonzales & Gonzales Bonds and Insurance Agency, Inc., American Surety Company. Motion Hearing set for 12/17/2015 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Edward M. Chen. Signed by Judge Edward M. Chen on 10/26/15. (bpf, COURT STAFF) (Filed on 10/26/2015)

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Gary A. Nye, Esq. (Cal. Bar No. 126104) <[e-mail]>
David R. Ginsburg, Esq. (Cal. Bar No. 210900) <[e-mail]>
ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP
5820 Canoga Avenue, Suite 250
Woodland Hills, California 91367
Tel: [phone]; Fax: [phone]

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Attorneys for Defendants/Counterclaimants

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UNITED STATES DEPARTMENT OF JUSTICE
Kirk Manhardt
E. Kathleen Shahan <[e-mail]>
John Siemietkowski <[e-mail]>
Frances M. McLaughlin <[e-mail]>
Commercial Litigation Branch, Civil Division
P.O. Box 875
Washington, D.C. 20044-0875
Tel: [phone]; Fax: [phone]

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Attorneys for Plaintiff/Counter-Defendants

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO DIVISION

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UNITED STATES OF AMERICA,

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Plaintiff,

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vs.

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GONZALES & GONZALES BONDS
AND INSURANCE AGENCY, INC. and
AMERICAN SURETY COMPANY, INC.,

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Case No. C 09-04029 EMC
Assigned to the
Honorable Edward M. Chen
STIPULATION AND [PROPOSED]
ORDER MODIFYING BRIEFING
SCHEDULE SET FORTH IN THE
CIVIL MINUTES OF OCTOBER 1, 2015

Defendants.
_____________________________________
GONZALES & GONZALES BONDS
AND INSURANCE AGENCY, INC. and
AMERICAN SURETY COMPANY, INC.
Counterclaimants,

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vs.

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UNITED STATES DEPARTMENT OF
HOMELAND SECURITY, et al.

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Counterdefendants.

STIPULATION TO ENLARGE TIME

Case No. C 09-04029 EMC

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Pursuant to Civil L.R. 6-1, 6-2, and 7-12, the parties, by and through their respective
counsel of record, stipulate and agree as follows:

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1.

The Court’s Civil Minutes dated October 1, 2015, provide that if the parties are

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unable to resolve a dispute over the methodology of fees and penalties, defendants are to file

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their motion on the issue by November 5, 2015, and plaintiff is to file its opposition by

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November 29, 2015, which is aSunday. A hearing on the motion and further case management

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conference is set for December 17, 2015. Dkt. No. 263.

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2.

The parties seek to enlarge the deadlines set forth in the Civil Minutes, and

propose that the due date for defendant’s brief be set for November 12, 2015, and the due date
for plaintiff’s opposition be set for December 3, 2015.

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3.

The parties make this request because defendants seek an additional week to file

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their brief, as well as additional time to continue meet and confer efforts. Plaintiff’s request the

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additional time so that work on any opposition need not take place around the Thanksgiving

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holiday.

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4.

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This is the first proposed time modification regarding this briefing schedule.

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STIPULATION TO ENLARGE TIME

Case No. C 09-04029 EMC

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5.

The requested enlargement of time would not affect the schedule for the case.

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IT IS SO STIPULATED.

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Dated: October 26, 2015

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ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP

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/s/ Gary A. Nye
GARY A. NYE
DAVID R. GINSBURG

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Attorneys for Defendants/Counterclaimants
Gonzales & Gonzales Bonds and Insurance
Agency, Inc. and American Surety Company, Inc.

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Benjamin C. Mizer
Principal Deputy
Assistant Attorney General
Civil Division
MELINDA HAAG
United States Attorney
/s/ John J. Siemietkowski
KIRK MANHARDT
E. KATHLEEN SHAHAN
(D.C. Bar No. 267872)
JOHN J. SIEMIETKOWSKI
(PA Bar. No. 50346)
FRANCES M. MCLAUGHLIN
(FL Bar No. 0256640)
U.S. Department of Justice
Commercial Litigation Branch

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Attorneys for the United States of
America

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STIPULATION TO ENLARGE TIME

Case No. C 09-04029 EMC

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Defendant's brief due 11/11/15.
Plaintiff's response due 11/25/15.
Motion hearing set for 12/17/15 at 1:30 p.m.

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____________________________________
TE
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AHONORABLE EDWARD M. CHEN
THE
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UNITED STATES DISTRICT JUDGE

10/26/15

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Dated:

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STIPULATION TO ENLARGE TIME

Case No. C 09-04029 EMC