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

Filing 83

STIPULATION AND ORDER SETTING SCHEDULE FOR THE PARTIES JOINT APPENDIX OF EXHIBITS AND REQUEST FOR JUDICIAL NOTICE IN SUPPORT OF THEIR CROSS-MOTIONS FOR SUMMARY JUDGMENT. Signed by Judge Richard Seeborg on 12/10/15. (cl, COURT STAFF) (Filed on 12/10/2015)

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SEDGWICK LLP
Ralph A. Guirgis (State Bar. No. 143262)
[e-mail]
Michael L. Fox (State Bar No. 173355)
[e-mail]
Jenni K. Katzer (State Bar No. 253684)
[e-mail]
333 Bush Street, 30th Floor
San Francisco, CA 94104-2834
Tel.: [phone] / Fax: [phone]

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Attorneys for Defendant
BRIT UW LIMITED
(sued as “Certain Underwriters at Lloyd’s
Under Policy No. B0146LDUSA701030”)
LAW OFFICES OF GEORGE
DONALDSON
George Donaldson (State Bar No. 77971)
[e-mail]
2298 Durant Avenue
Berkeley, CA 94707
Tel.: [phone] / Fax: [phone]
Attorneys for Plaintiffs
WILLIAM AMBROSIO, et al.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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WILLIAM AMBROSIO, an individual; et al.,

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

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

STIPULATION AND [PROPOSED]
ORDER SETTING SCHEDULE FOR
THE PARTIES JOINT APPENDIX OF
EXHIBITS AND REQUEST FOR
JUDICIAL NOTICE IN SUPPORT OF
THEIR CROSS-MOTIONS FOR
SUMMARY JUDGMENT

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Plaintiffs William Ambrosio, et al. (collectively, “Ambrosio Plaintiffs” or “Plaintiffs”)

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and Defendant Brit UW Limited (“Brit” or “Defendant”) (sued as “Certain Underwriters at

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Lloyd’s Under Policy No. B0146LDUSA701030”), by their attorneys of record, AGREE AND

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STATE AS FOLLOWS:

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-13:11-cv-04956-RS
STIPULATION AND [PROPOSED] ORDER SETTING SCHEDULE FOR THE PARTIES' JOINT APPENDIX
OF EXHIBITS AND REQUEST FOR JUDICIAL NOTICE ISO THEIR CROSS-MOTIONS FOR SUMMARY
JUDGMENT

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A.

judgment on December 10, 2015, the last day for filing dispositive motions;

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B.

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exhibits; and
C.

which the exhibits can be/need to be highlighted.
After discussion with the Court’s legal research attorney, Plaintiffs and Defendants
have agreed and STIPULATE AS FOLLOWS:

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1.

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after which Plaintiffs will add their marks and annotations to the exhibits;
2.

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If Plaintiffs provide Defendants their annotations before the end of the day on

Monday, December 14, 2015, then Defendants will file the Joint Appendix of Exhibits and
Request for Judicial Notice on Tuesday, December 15, 2015;

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Defendant will provide electronic copies of its highlighted exhibits to

Plaintiffs immediately after the Court’s execution of this Stipulation and [Proposed] Order,

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Plaintiffs and Defendants have collaborated on a Joint Appendix of Exhibits

and a Joint Request for Judicial Notice but, at the last minute, disagreed on the extent to

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Plaintiffs and Defendant anticipated having to file extensive documents in

support of their cross-motions and, for the Court’s benefit, have agreed to coordinate their

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Both the Plaintiffs and Defendant intended to file cross-motions for summary

3.

If Plaintiffs have not provided Defendants with their annotations before the

end of the day on Monday, December 14, 2015, then Plaintiffs will file the Joint Appendix of
Exhibits and Request for Judicial Notice on Tuesday, December 15, 2015; and
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-23:11-cv-04956-RS
STIPULATION AND [PROPOSED] ORDER SETTING SCHEDULE FOR THE PARTIES' JOINT APPENDIX
OF EXHIBITS AND REQUEST FOR JUDICIAL NOTICE ISO THEIR CROSS-MOTIONS FOR SUMMARY
JUDGMENT

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4.

The filing of the Joint Appendix of Exhibits and Request for Judicial Notice

shall be deemed timely and shall not prejudice the parties’ cross-motions for summary
judgment.
IT IS SO STIPULATED.

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Respectfully submitted,
DATED: December 10, 2015

SEDGWICK LLP

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By: /s/ Michael L. Fox
Michael L. Fox
Jenni K. Katzer
Attorneys for Defendant
BRIT UW LIMITED (sued as “Certain Underwriters
at Lloyd’s Under Policy No. B0146LDUSA0701030”)

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DATED: December 10, 2015

LAW OFFICES OF GEORGE DONALDSON

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By: /s/ George Donaldson
George Donaldson
Attorney for Plaintiffs
WILLIAM AMBROSIO, et al.

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IT IS SO ORDERED.
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Dated: 12/10/15

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HON. RICHARD SEEBORG
UNITED STATES DISTRICT JUDGE

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ATTESTATION

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I, Michael L. Fox, am the ECF user whose User ID and Password are being used to file

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the STIPULATION AND [PROPOSED] ORDER SETTING BRIEFING SCHEDULE RE

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PARTIES’ CROSS-MOTIONS FOR SUMMARY JUDGMENT. In compliance with General

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Order 45.X.B, I hereby attest that concurrence in the filing of this document has been obtained

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from signatory George Donaldson.

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Dated: December 10, 2015

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SEDGWICK LLP
BY:

/s/ Michael L. Fox
Michael L. Fox

-33:11-cv-04956-RS
STIPULATION AND [PROPOSED] ORDER SETTING SCHEDULE FOR THE PARTIES' JOINT APPENDIX
OF EXHIBITS AND REQUEST FOR JUDICIAL NOTICE ISO THEIR CROSS-MOTIONS FOR SUMMARY
JUDGMENT