Michael Taylor Designs, Inc. v. Travelers Property Casualty Company of America

Filing 48

STIPULATION AND ORDER RE 47 TO CONTINUE HEARING DATE ON PLAINTIFF'S MOTION FOR PARTIAL SUMMARY JUDGMENT RE QUANTIFICATION OF DAMAGES. Motion Hearing set for 4/14/2011 01:30 PM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Signed by Judge Richard Seeborg on 3/18/11. (cl, COURT STAFF) (Filed on 3/18/2011)

*E-Filed 3/18/11* 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Attorneys for Plaintiff Michael Taylor Designs, Inc. 15 16 17 18 19 20 21 22 23 24 25 26 27 28 TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA, a Connecticut corporation, Defendant. MICHAEL TAYLOR DESIGNS, INC., a California corporation, Plaintiff, v. CASE NO. C10-02432-RS STIPULATED REQUEST TO CONTINUE HEARING DATE ON PLAINTIFF'S MOTION FOR PARTIAL SUMMARY JUDGMENT RE QUANTIFICATION OF DAMAGES Former Hearing Date: April 7, 2011 Requested New Hearing Date: April 14, 2011 Time: 1:30 p.m. Judge: Hon. Richard Seeborg Court: Courtroom 3, 17th Floor UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA GAUNTLETT & ASSOCIATES David A. Gauntlett (SBN 96399) James A. Lowe (SBN 214383) Andrew M. Sussman (SBN 112418) 18400 Von Karman, Suite 300 Irvine, California 92612 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] [e-mail] Attorneys for Defendant Travelers Property Casualty Company Of America SEDGWICK, DETERT, MORAN & ARNOLD LLP BRUCE D. CELEBREZZE Bar No. 102181 [e-mail] MATTHEW C. LOVELL Bar No. 189728 [e-mail] One Market Plaza Steuart Tower, 8th Floor San Francisco, California 94105 Telephone: [phone] Facsimile: [phone]

PLEASE TAKE NOTICE THAT counsel for defendant Travelers Property Casualty Company of America ("Travelers") and plaintiff Michael Taylor Designs, Inc. ("MTD") (collectively, "the Parties") agree and stipulate as follows:
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CASE NO. C10-02432-RS

Stipulated Request for an Order Continuing Hearing re Motions re Quantification of Damages

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1.

WHEREAS, MTD filed a Motion for Partial Summary Judgment Re: Quantification

of Damages ("the Motion") on January 28, 2011 (ECF Nos. 39-42); 2. WHEREAS, on February 7, 2011, this Court issued an Order that: "continued the

hearing on the Motion to April 7, 2011, with the deadline for any opposition extended accordingly[,]" and directed the parties to meet and confer to resolve or narrow their disputes concerning the issues raised in the Motion (ECF No. 43, at 2:5-9); 3. WHEREAS, the Parties have agreed on the terms of a resolution of the issues raised

in the Motion, and wish to continue the hearing date, opposition date, and reply date set for the Motion to allow the Parties to prepare and submit a proposed stipulated judgment that would resolve the Motion and terminate this action, reserving all rights of appeal; NOW, THEREFORE, THE PARTIES STIPULATE, AND REQUEST THE COURT TO ORDER, AS FOLLOWS: 1. The April 7, 2011 hearing date for the Motion (ECF Nos. 39-42) shall be continued

to April 14, 2011, at 1:30 p.m., 2. The opposition and reply dates for the Motion shall be continued accordingly, to

March 24, 2011 and March 31, 2011, respectively. IT IS SO STIPULATED DATED: March 17, 2011 SEDGWICK, DETERT, MORAN & ARNOLD LLP

By:

/s/ Matthew C. Lovell Bruce D. Celebrezze Matthew C. Lovell Attorneys for Defendant Travelers Property Casualty Company of America

DATED: March 17, 2011 24 25

GAUNTLETT & ASSOCIATES

By: 26 27 28
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/s/ Andrew M. Sussman Andrew M. Sussman Attorneys for Plaintiff Michael Taylor Designs, Inc.

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CASE NO. C10-02432-RS

Stipulated Request for an Order Continuing Hearing re Motions re Quantification of Damages

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ATTESTATION OF FILING Pursuant to General Order 45.X.B, I attest that I have obtained concurrence in the filing of this document from the parties listed above. /s/ Matthew C. Lovell Matthew C. Lovell

IT IS SO ORDERED:

____________________________________ RICHARD SEEBORG UNITED STATES DISTRICT JUDGE 3/18/11 DATED: ________________________

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CASE NO. C10-02432-RS

Stipulated Request for an Order Continuing Hearing re Motions re Quantification of Damages