Rafanelli et al v. Travelers Property Casualty Company of America

Filing 22

ORDER VACATING HEARING DATE. Signed by Judge Samuel Conti on 12/28/2012. (sclc1, COURT STAFF) (Filed on 12/28/2012)

Case3:12-cv-04141-SC Document21 Filed12/21/12 Page1 of 3

1
2
3
4
5
6
7
8
9
10

JOHN F. FRIEDEMANN (SBN 115632)
[e-mail]
KYLE M. FISHER (SBN 127334)
[e-mail]
MARCI A. REICHBACH (SBN 215545)
[e-mail]
FRIEDEMANN GOLDBERG LLP
420 Aviation Boulevard, Suite 201
Santa Rosa, California 95403
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs
DAVID RAFANELLI, PATRICIA RAFANELLI,
A. RAFANELLI WINERY & VINEYARDS
LIMITED PARTNERSHIP dba A. RAFANELLI
WINERY & VINEYARDS, RAFANELLI MANAGEMENT
LLC, RASHELL L. RAFANELLI-FEHLMAN
and RLF MANAGEMENT LLC

11
12

UNITED STATES DISTRICT COURT

13

FOR THE NORTHERN DISTRICT OF CALIFORNIA

14
15
16
17
18
19

DAVID RAFANELLI, an individual; PATRICIA
RAFANELLI, an individual; A. RAFANELLI
WINERY & VINEYARDS LIMITED
PARTNERSHIP dba A. RAFANELLI WINERY
& VINEYARDS, a California limited
partnership; RAFANELLI MANAGEMENT
LLC, a California limited liability company;
RASHELL L. RAFANELLI-FEHLMAN an
individual; and RLF MANAGEMENT LLC, a
California limited liability company;

20

Case No. 3:12-cv-04141-SC
NOTICE OF SETTLEMENT OF ENTIRE
CASE AND STIPULATION AND
[PROPOSED] ORDER VACATING
MOTION HEARING DATE
Assigned To: Hon. Samuel Conti
Trial Date:

Not Set

Plaintiffs,
21
vs.
22
23

TRAVELERS PROPERTY CASUALTY
COMPANY OF AMERICA, a Connecticut
corporation,

24
Defendant.
25
26
27
28
{00259574.DOC;v1}

NOTICE OF SETTLEMENT OF ENTIRE CASE AND STIPULATION AND [PROPOSED] ORDER VACATING
MOTION HEARING DATE

Case3:12-cv-04141-SC Document21 Filed12/21/12 Page2 of 3

1
2

TO THE CLERK OF THE COURT AND ALL PARTIES AND THEIR
ATTORNEYS OF RECORD:

3

PLEASE TAKE NOTICE that on or about December 20, 2012 Plaintiffs David

4

Rafanelli, Patricia Rafanelli, A. Rafanelli Winery & Vineyards Limited Partnership dba A.

5

Rafanelli Winery & Vineyards, Rafanelli Management LLC, Rashell L. Rafanelli-Fehlman and

6

RLF Management LLC (collectively “Rafanelli”) and Defendant Travelers Property Casualty

7

Company of America (“Travelers”) (together the “Parties”) agreed to the terms of a conditional

8

settlement.

9
10

This stipulation is entered into by the Parties by and through their respective counsel of
record.

11
12

FACTUAL RECITALS

13

This Stipulation is entered into in reference to the following facts:

14

1.

The initial pleading in this case was filed on August 6, 2012.

15

2.

The Parties have pending motions for summary judgment set for hearing on

16

January 11, 2012 which the Parties wish to withdraw.

17

3.

18

The Parties anticipate that it will take 30 days to finalize the settlement agreement
and for Travelers to satisfactorily complete the terms of the settlement.

19

4.

20

The Parties anticipate that they will be able to file a stipulation of dismissal within
approximately 45 days.

21

///

22

///

23

///

24

///

25

///

26

///

27

///

28

///
1
NOTICE OF SETTLEMENT OF ENTIRE CASE AND STIPULATION AND [PROPOSED] ORDER VACATING
MOTION HEARING DATE

{00259574.DOC;v1}

Case3:12-cv-04141-SC Document21 Filed12/21/12 Page3 of 3

1

STIPULATION

2

In light of the foregoing facts, the Parties agree as follows:

3

1.

4

The hearing date on the motions for summary judgment scheduled for January 11,
2013 shall be vacated.

5
6

SO STIPULATED.

7
8

DATED: December 21, 2012

FRIEDEMANN GOLDBERG LLP

9
10

By: /s/ Marci A. Reichbach
MARCI A. REICHBACH
Attorneys for Plaintiffs
DAVID RAFANELLI, PATRICIA RAFANELLI, A.
RAFANELLI WINERY & VINEYARDS LIMITED
PARTNERSHIP dba A. RAFANELLI WINERY &
VINEYARDS, RAFANELLI MANAGEMENT LLC,
RASHELL L. RAFANELLI-FEHLMAN and RLF
MANAGEMENT LLC

11
12
13
14
15
16

DATED: December 21, 2012

SEDGWICK LLP

17
18

By: /s/ Nicholas J. Boos
NICHOLAS J. BOOS
Attorneys for Defendant
TRAVELERS PROPERTY CASUALTY COMPANY
OF AMERICA

19
20
21
22
23
24

Filer's Attestation: Pursuant to Civil Local Rule 5-1 (i)(3) regarding signatures, Marci A.
Reichbach hereby attests that concurrence in the filing of this document has been obtained.
PURSUANT TO STIPULATION, IT IS SO ORDERED.

25
26

DATED: December 28, 2012
UNITED STATES DISTRICT COURT JUDGE

27
28

2
NOTICE OF SETTLEMENT OF ENTIRE CASE AND STIPULATION AND [PROPOSED] ORDER VACATING
MOTION HEARING DATE

{00259574.DOC;v1}