Ambrosio et al v. Certain Underwriters at Lloyd's Under Policy No. B0146LDUSA0701030

Filing 15

ORDER JOINT STIPULATED REQUEST FOR ESTABLISHING BRIEFING SCHEDULE AND HEARING DATE RELATING TO DEFENDANT'S MOTIONS TO DISMISS AND MOTIONS TO STRIKE.Motion Hearing set for 1/5/2012 01:30 PM in Courtroom 3, 17th Floor, San Francisco before Hon. Richard Seeborg. Signed by Judge Richard Seeborg on 10/24/11. (cl, COURT STAFF) (Filed on 10/24/2011)

*E-Filed 10/24/11*

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Jeffrey A. Feldman - Bar No. 154440
[e-mail]
Thomas H. Porter - Bar No. 178998
[e-mail]
Law Offices of Jeffrey A. Feldman
425 California Street, Suite 2025
San Francisco, CA 94104
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Alvarado Plaintiffs

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[Additional Counsel for Plaintiffs appear on signature page]

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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WILLIAM AMBROSIO et al.,

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CASE NO. 3:11-cv-04956-RS

Plaintiffs,
JOINT STIPULATED REQUEST FOR
ORDER ESTABLISHING BRIEFING
SCHEDULE AND HEARING DATE
RELATING TO DEFENDANT’S
MOTIONS TO DISMISS AND MOTIONS
TO STRIKE

v.
CERTAIN UNDERWRITERS AT
LLOYD'S UNDER POLICY NO.
B0146LDUSA0701030 and DOES 1 through
100, inclusive,
Defendants.

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CASE NO. 3:11-cv-04957-RS

MICHAEL ALVARADO et al.,
Plaintiffs,

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v.

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CERTAIN UNDERWRITERS AT
LLOYD’S UNDER POLICY NO.
B0146LDUSA0701030, and DOES 1-100,
inclusive,

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Defendants.

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Joint Stipulation Re Briefing Schedule

3:11-cv-04956-RS

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WILLIAM JAMISON et al.,

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CASE NO. 3:11-cv-04958-RS

Plaintiffs,
v.
CERTAIN UNDERWRITERS AT
LLOYD'S UNDER POLICY NO.
B0146LDUSA0701030 and DOES 1 through
100, inclusive,

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Defendants.
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Plaintiffs William Ambrosio et al., Case No. 3:11-cv-04956-RS, by and through their
counsel of record, George Donaldson from the Law Office of George Donaldson;
Plaintiffs Michael Alvarado, et al., Case No. 3:11-cv-04957-RS, by and through their

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counsel of record, Jeffrey A. Feldman from the Law Offices of Jeffrey A. Feldman;
Plaintiffs William Jamison, et al., Case No. 3:11-cv-04958-RS, by and through their
counsel of record, Val Hornstein from the Hornstein Law Offices; and

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Defendant Brit UW Limited (“Brit”), Case Numbers 3:11-cv-04956-RS, 3:11-cv-04957-

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RS, 3:11-cv-04958-RS, by and through its counsel of record, Michael L. Fox of Sedgwick LLP,

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hereby stipulate as follows:

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WHEREAS Defendant Brit has filed Motions to Dismiss pursuant to Federal Rule of Civil
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Procedure 12(b)(6) with respect to Plaintiffs’ respective Complaints filed in the above captioned

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cases, which cases were removed from Marin County Superior Court to the United States District

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Court, Northern District of California, on or about October 7, 2011;

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WHEREAS Defendant has also filed Motions to Strike pursuant to Federal Rule of Civil
Procedure 12(f) with respect to Plaintiffs’ prayer for punitive damages in each of the above
referenced cases;

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WHEREAS the parties entered into a Joint Stipulation to Relate Cases as to the following
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Joint Stipulation Re Briefing Schedule

3:11-cv-04956-RS

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matters: William Ambrosio et al. v. Certain Underwriters at Lloyd’s, Case Number 3:11-cv-

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04956-RS, Michael Alvarado, et al. v. Certain Underwriters at Lloyd’s, Case Number 3:11-cv-

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04957-RS, and William Jamison, et al. v. Certain Underwriters at Lloyd’s, Case Number 3:11-cv-

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04958-RS;
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WHEREAS the Court has granted the administrative motion to relate these cases, and

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each of the above referenced cases in now assigned to the Honorable Judge Seeborg;
WHEREAS attorneys for Plaintiffs and Defendant in these matters now desire to establish

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a hearing date relating to Defendants’ Motions to Dismiss and Motions to Strike filed in each

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case, and establish a revised briefing schedule relating thereto, including the filing of a joint

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opposition by Plaintiffs in order to eliminate unnecessary duplication of labor and cost; and

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WHEREAS there have been no previous time modifications in this case and the

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Stipulation between the parties will have no effect on the schedule for the case;
NOW THEREFORE, IT IS HEREBY STIPULATED by and between the parties that,

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subject to the Court’s approval, the hearing relating to Defendants’ Motions to Dismiss and
January 5, 2012
Motions to Strike filed in the three cases will be scheduled for December 15, 2011 at 1:30 pm;
December 5, 2011
Plaintiffs’ joint opposition papers to Defendant’s motions will be due November 14, 2011; and
December 19, 2011
Defendants’ Reply papers will be due November 28, 2011.

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DATED: October 24, 2011

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LAW OFFICES OF GEORGE DONALDSON
By: /s/ George Donaldson____________
George Donaldson
Attorneys for Ambrosio Plaintiffs
Case No. 3:11-cv-04956-RS

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Joint Stipulation Re Briefing Schedule

3:11-cv-04956-RS

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DATED: October 24, 2011

LAW OFFICES OF JEFFREY A. FELDMAN

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By: /s/ Jeffrey A. Feldman___________
Jeffrey A. Feldman
Attorneys for Alvarado Plaintiffs
Case No. 3:11-cv-04957-RS

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DATED: October 24, 2011

HORNSTEIN LAW OFFICES

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By: /s/ Val Hornstein_______________
Val Hornstein
Attorneys for Jamison Plaintiffs
Case No. 3:11-cv-04958-RS

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DATED: October 24, 2011

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SEDGWICK LLP
By: /s/ Michael L. Fox_______________
Michael L. Fox
Attorneys for Defendant Brit UW Limited
(sued as Certain Underwriters at Lloyd’s)

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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Dated: October _______, 2011

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__________________________________
Hon. Richard Seeborg, Judge
United States District Court

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Joint Stipulation Re Briefing Schedule

3:11-cv-04956-RS