California Capital Insurance Company v. Travelers Property Casualty Company of America

Filing 16

STIPULATION AND ORDER re 15 STIPULATION WITH PROPOSED ORDER re 11 Case Management Scheduling Order, filed by California Capital Insurance Company Case Management Statement due by 1/16/2014. Case Management Conference set for 1/23/2014 09:00 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 11/19/13. (bpfS, COURT STAFF) (Filed on 11/19/2013)

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GRANT, GENOVESE & BARATTA, LLP
2030 Main Street, Suite 1600
Irvine, California 92614
Telephone: [phone]
Facsimile: [phone]
2206-471

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James M. Baratta (SBN 54890)
Christopher S. Dunakin (SBN 192096)
Jenifer A. Pearl (SBN 228336)
[e-mail]; [e-mail]; [e-mail]

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Attorneys for Plaintiff CALIFORNIA CAPITAL
INSURANCE COMPANY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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CALIFORNIA CAPITAL INSURANCE
COMPANY, a California corporation,
Plaintiff,

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Case No. CV 13 03809-EMC
[Removed from Sonoma County Superior
Court Case No. SCV-253936]
STIPULATION AND [PROPOSED]
ORDER OF THE PARTIES
CONTINUING THE DECEMBER 12, 2013
CASE MANAGEMENT CONFERENCE
AND RELATED ADR DEADLINES

vs.
TRAVELERS PROPERTY CASUALTY
COMPANY OF AMERICA, a Connecticut
corporation; and DOES 1 to 30, Inclusive,

Filed: 7/10/2013
Trial Date:
None set

Defendants.

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WHEREAS, Christopher S. Dunakin and Jenifer A. Pearl, with Grant, Genovese & Baratta,

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LLP, counsel for California Capital Insurance Company have a scheduling conflict with the Court’s

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recently rescheduled date of December 12, 2013 for the Case Management Conference. Mr. Dunakin

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has prior scheduled depositions and Ms. Pearl has a previously scheduled mediation.

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WHEREAS the parties to this action, Plaintiff and defendant, Travelers Property Casualty
Company of America stipulate to a continuance of the Case Management Conference to a date suitable
for the Court and both parties.

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE
Case No. CV 13 3809-LB

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Accordingly, the parties, through their counsel of record hereby stipulate to continue the Case

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Management Conference to Thursday, January 23, 1014 at 9:00 a.m. Further, the parties also stipulate

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to the related ADR deadlines as follows: 1) January 16, 2014 – Last day to file a Rule 26(f) Report and

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Joint Case Management Statement; and 2) February 6, 2014 – Last day to complete initial disclosures or

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state objection in Rule 26(f) Report.

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IT IS SO STIPULATED.

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Date: November 18, 2013

SEDGWICK LLP

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By: /s/ Erin A. Cornell
BRUCE D. CELEBREZZE
MICHAEL A. TOPP
ERIN A. CORNELL
Attorneys for Defendant TRAVELERS
PROPERTY CASUALTY COMPANY OF
AMERICA

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Date: November 18, 2013

GRANT, GENOVESE & BARATTA, LLP

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By: /s/ Jenifer A. Pearl
CHRISTOPHER S. DUNAKIN
JENIFER A. PEARL
Attorneys for Plaintiff CALIFORNIA CAPITAL
INSURANCE COMPANY

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IT IS SO ORDERED.
11/19/13

DATED: ____________________

S DISTRICT
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TA

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_______________________________ ERE
O ORD
IT IS S CHEN FIED
HONORABLE EDWARD M. ODI
AS M
UNITED STATES DISTRICT JUDGE

NO

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en

d M. Ch

dwar
Judge E

R NIA

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complete initial disclosures or state objection in Rule 26(f) Report.

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January 16, 2014

Rule 26(f) Report and Joint Case Management Statement; and 2) February 6, 2014 – Last day to

FO

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Further, the Court orders the related ADR deadlines as follows 1) January 16, 2014 – Last day to file a

LI

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orders that the Case Management Conference is continued to Thursday, January 23, 2014 at 9:00 a.m.

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STIPULATION AND [PROPOSED] ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE
ER
Case No. CV 13 3809-LB
C

A

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Based on the stipulation of the parties and good cause appearing therefrom, the Court hereby

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ORDER

UNIT
ED

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N

F
D IS T IC T O

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California Capital Ins. Co. v. Travelers Property Casualty Co. of America, et al.
United States District Court Case No. CI3-3809 EMC
File No. 2206-471
PROOF OF SERVICE

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I am a citizen of the United States over the age of 18 and not a party to the within
action. I am an employee of Grant, Genovese & Baratta, LLP and my business address is
2030 Main Street, Suite 1600, Irvine CA 92614. On November 18, 2013, I served the
foregoing documents described as:
STIPULATION AND [PROPOSED] ORDER OF THE PARTIES CONTINUING
THE DECEMBER 12, 2013 CASE MANAGEMENT CONFERENCE AND
RELATED ADR DEADLINES
BY MAIL. I am familiar with the practice of Grant, Genovese & Baratta, LLP for
collection and processing of correspondence for mailing with the United States Postal
Service. Correspondence so collected and processed is deposited with the United States
Postal Service that same day in the ordinary course of business. On this date, a copy of
said document was placed in a sealed envelope, with postage fully prepaid, addressed as
set forth herein, and such envelope was placed for collection and mailing at Grant,
Genovese & Baratta, LLP, Irvine, California, following ordinary business practices.
Bruce D. Celebrezze
Michael A. Topp
Erin A. Cornell
SEDGWICK LLP
333 Bush Street, 30th Floor
San Francisco, CA 94101-2834
[phone]
[phone]-Facsimile
Attorney for Defendant TRAVELERS PROPERTY CASUALTY COMPANY OF
AMERICA
I declare that I am employed in the office of a member of the bar of this court at
whose direction the services was made. I declare under penalty of perjury under the laws
of the United States of America that the foregoing is true and correct, and that this
declaration was executed on November 18, 2013 at Irvine, California.

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/s/ Frances Pham
Frances Pham, Declarant

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PROOF OF SERVICE