State Farm Mutual Automobile Insurance Company v. United State of America

Filing 9

ORDER by Magistrate Judge Maria-Elena James granting 8 Stipulation Extending Time for Defendant to Respond to Complaint and Continuing Initial Case Management Conference. (rmm2S, COURT STAFF) (Filed on 1/14/2013)

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MELINDA HAAG (CABN 132612)
United States Attorney

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ALEX G. TSE (CSBN 152348)
Chief, Civil Division

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MARK R. CONRAD (CSBN 255667)
Assistant United States Attorney

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450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: [phone]
Fax: [phone]
Email: [e-mail]

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Attorneys for Defendants
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REESE LAW GROUP
Joseph M. Pleasant (CSBN179571)
6725 Mesa Ridge Road, Suite 240
San Diego, CA 92121
Telephone: [phone]
Fax: [phone]
Email: [e-mail]

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Attorneys for Plaintiff

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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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STATE FARM AUTOMOBILE
INSURANCE COMPANY,
Plaintiff,

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v.
UNITED STATES OF AMERICA,
Defendant.

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STIPULATION EXTENDING TIME
Case No. C 12-04678 MEJ

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No. C 12-04678 MEJ
STIPULATION EXTENDING TIME
FOR DEFENDANT TO RESPOND TO
COMPLAINT AND CONTINUING
INITIAL CASE MANAGEMENT
CONFERENCE AND [PROPOSED]
ORDER

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Pursuant to Northern District Civil Local Rules 6-1(a), 7-12, and 16-2(d), Plaintiff State

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Farm Mutual Automobile Insurance Company and Defendant United States of America hereby

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submit the following stipulation and proposed order extending the time for Defendant to respond

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to the Complaint and continuing the Initial Case Management Conference in this action.

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*****

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WHEREAS, on September 7, 2012, Plaintiff filed this subrogation action seeking

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$5,000.98 in damages in connection with an insurance claim that was paid by Plaintiff to a

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policyholder involved in a motor vehicle accident with an individual allegedly acting at the time

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within the course and scope of his employment by the United States Mint;
WHEREAS, on January 11, 2013, the parties filed a Stipulation for Compromise

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Settlement and Release (“Settlement Agreement”), which would resolve all claims asserted in

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this action, see Dkt. No. 7;
WHEREAS, the Settlement Agreement contemplates the entry of a Stipulation of

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Dismissal with Prejudice upon payment by Defendant of the Settlement Amount described

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therein, see id. ¶¶ 3, 5 & Ex. A;

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NOW, THEREFORE, to provide the parties with additional time to fulfill the obligations

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undertaken by them under the Settlement Agreement, such that the above-referenced stipulation

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of dismissal may be entered without need for further proceedings before this Court, it is hereby

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agreed by Plaintiff and Defendant that:
(1) Defendant’s deadline to respond to the Complaint in this action shall be extended by

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one-hundred-and-twenty (120) days, until and including Tuesday, May 14, 2013; and
(2) the Initial Case Management Conference set in this action shall be continued until

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May 30, 2013, at 10:00 a.m. and all other deadlines set by the Court in its Order Setting Initial

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Case Management Conference shall be continued by the same interval, such that the parties’

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STIPULATION EXTENDING TIME
Case No. C 12-04678 MEJ

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Case Management Statement(s) shall be due on or before May 23, 2013, and the meet-and-

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confer deadlines set in the Court’s order shall be May 9, 2013.

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IT IS SO STIPULATED.

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Respectfully submitted,

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DATED: January 11, 2013

MELINDA HAAG
United States Attorney

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/s/ Mark R. Conrad
MARK R. CONRAD
Assistant United States Attorney
Attorneys for Defendant

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DATED: January 11, 2013

REESE LAW GROUP
Joseph M. Pleasant

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/s/ Joseph M. Pleasant
JOSEPH M. PLEASANT
Attorneys for Plaintiff

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STIPULATION EXTENDING TIME
Case No. C 12-04678 MEJ

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[PROPOSED] ORDER

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Pursuant to the stipulation of the parties, the Court hereby ORDERS that the deadline for

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Defendant to respond to the Complaint in this action shall be extended until and including May

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14, 2013; and further ORDERS that the Initial Case Management Conference in this matter set

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for February 7, 2013, is hereby VACATED and CONTINUED until May 30, 2013, at 10:00 a.m.

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The parties shall file a Joint Case Management Statement not later than May 23, 2013.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: _______________2013
January 14,

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HONORABLE MARIA-ELENA JAMES
Chief Magistrate Judge

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STIPULATION EXTENDING TIME
Case No. C 12-04678 MEJ

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