Rosen v. Encompass Insurance Company

Filing 24

STIPULATION AND ORDER re 23 to Extend Early Neutral Evaluation Deadline and Continue Case Management Conference filed by Encompass Insurance Company Case Management Statement due by 4/11/2013. Further Case Management Conference set for 4/18/2013 10:30 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 12/13/12. (bpf, COURT STAFF) (Filed on 12/13/2012)

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CHARLES COCHRAN (State Bar No. 98064)
RACHAEL ERICKSON (State Bar No. 217445)
COCHRAN ERICKSON, PC
50 Old Courthouse Square, Suite 601
Santa Rosa, California 95404
Telephone: [phone]
Facsimile: [phone]
Email:
[e-mail]

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Attorneys for Plaintiff
BARRY ROSEN

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SNR DENTON US LLP
525 MARKET STREET, 26TH FLOOR
SAN FRANCISCO, CALIFORNIA 94105-2708
[phone]

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CYNTHIA L. MELLEMA (State Bar No. 122798)
JEFFRY BUTLER (State Bar No. 180936)
MEGAN BARKER (State Bar No. 245991)
SNR Denton US LLP
525 Market Street, 26th Floor
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Emails: [e-mail]
[e-mail]
[e-mail]

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Attorneys for Defendant
ENCOMPASS INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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BARRY ROSEN,
Plaintiff,

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No. 3:12-cv-03753-EMC
STIPULATION TO EXTEND EARLY
NEUTRAL EVALUATION
DEADLINE AND CONTINUE CASE
MANAGEMENT CONFERENCE
AND [PROPOSED] ORDER

vs.
ENCOMPASS INDEMNITY COMPANY
and DOES 1 through 50
Defendants.

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CASE NO. . 3:12-cv-03753-EMC

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STIPULATION TO EXTEND DEADLINES
AND [PROPOSED] ORDER

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Plaintiff Barry Rosen and defendant Encompass Insurance Company, by and through their

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respective counsel of record, hereby stipulate and agree as follows and respectfully request that the

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Court approve and give effect to their stipulation:

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1.

The Court has ordered the parties to complete early neutral evaluation by January 7,

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2.

The Court has set the next case management conference for March 14, 2013.

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3.

Based on the parties’ and the early neutral evaluator’s schedule and to allow the

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2012.

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parties additional time to adequately evaluate the case in order to conduct a meaningful evaluation

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session, the parties request that the Court continue the deadline to complete the early neutral

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SNR DENTON US LLP
525 MARKET STREET, 26TH FLOOR
SAN FRANCISCO, CALIFORNIA 94105-2708
[phone]

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evaluation until April 8, 2013.
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The parties further request that the Court continue the March 14, 2013 case

management conference to a date convenient to the Court after April 8, 2013.

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IT IS SO STIPULATED.

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Pursuant to General Order No. 45, section X(B) regarding signatures, I attest under penalty

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of perjury that the concurrence in the filing of this document has been obtained from its signatories.

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Dated: December 11, 2012

By

Dated: December 11, 2012

COCHRAN ERICKSON, PC

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/s/ Megan Barker
MEGAN BARKER

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By

/s/ Charlie Cochran
CHARLIE COCHRAN
Attorneys for Plaintiff
BARRY ROSEN

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CASE NO. . 3:12-cv-03753-EMC

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STIPULATION TO EXTEND DEADLINES
AND [PROPOSED] ORDER

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Dated: December 11, 2012

SNR DENTON US LLP

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By

/s/ Megan Barker
MEGAN BARKER
Attorney for Defendant
ENCOMPASS INSURANCE COMPANY

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[PROPOSED] ORDER

April 8, 2013. It is further ordered that the case management conference currently set for March 14,

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April 18, 2013 at
2013 has been continued to _______________. 10:30 a.m. An updated joint CMC statement shall
be filed by April 11, 2013.
S

RT
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AS MO

dwa
Judge E

__________________________________
D
HON. EDWARD M. CHEN.
RDERE
S SO O ICourt Judge
United States District ED
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December 13, 2012
Dated: _______________

NO

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S DI TRICT
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UNIT
ED

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S

IT IS SO ORDERED that the deadline for the parties to complete early neutral evaluation is

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SNR DENTON US LLP
525 MARKET STREET, 26TH FLOOR
SAN FRANCISCO, CALIFORNIA 94105-2708
[phone]

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N

F
D IS T IC T O
R

C

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CASE NO. . 3:12-cv-03753-EMC

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STIPULATION TO EXTEND DEADLINES
AND [PROPOSED] ORDER