Nelson v. Hartford Life Insurance Company

Filing 89

ORDER Further Case Management Conference reset for 5/22/2015 08:30 AM in Courtroom 6, 17th Floor, San Francisco. Signed by Judge Charles R. Breyer on 3/20/2015. (beS, COURT STAFF) (Filed on 3/23/2015)

1 Emilie E. de la Motte (SBN: 233557)
[e-mail]
2 MEYERS, NAVE, RIBACK, SILVER & WILSON
555 12th Street, Suite 1500
3 Oakland, California 94607
Telephone: [phone]
4 Facsimile: [phone]
5 Attorneys for Third-Party Defendant/CrossClaimant CITY OF OAKLAND
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA, SAN FRANCISCO DIVISION

10 DESSIE R. NELSON,

Case No. 13-CV-04196-CRB

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STIPULATION REQUESTING
CONTINUANCE OF CASE
MANAGEMENT CONFERENCE;
ORDER

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Plaintiff,
v.

13 THE HARTFORD, and DOES 1 through 10,
Inclusive,
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Defendants.
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HARTFORD LIFE INSURANCE
16 COMPANY,
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Trial Date:

None Set

Third-Party Plaintiff,
v.

19 JULIANA JAMES, as Administrator of the
Estate of Clarence James, CITY OF
20 OAKLAND, and ROES 1 through 50,
Inclusive,
21
Third-Party Defendants.
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CITY OF OAKLAND,
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Cross-Claimant,
24
v.
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JULIANA JAMES, as Administrator of the
26 Estate of Clarence James, and MOES 1
through 10, Inclusive,
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Cross-Defendants.
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13-CV-04196-CRB
STIPULATED REQUEST FOR CMC CONTINUANCE; [PROPOSED] ORDER

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COMES NOW Plaintiff Dessie Nelson, Defendant and Third-Party Complainant Hartford

2 Life Insurance Company (erroneously sued as “The Hartford”), Third-Party Defendant and Cross3 Claimant City of Oakland, and Third-Party Defendant and Cross-Defendant Juliana James
4 (collectively, “the Parties”), by and through their respective attorneys of record, and respectfully
5 ask the Court to continue the Case Management Conference, currently scheduled for April 3,
2015, for another forty-five (45) days. The Parties believe that good cause permits the Court to
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continue the conference. The Parties have informally agreed to settle all claims and cross-claims
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alleged in this lawsuit. The terms of the agreements have already been agreed upon by the Parties
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and their counsel. The Parties need, however, additional time to: 1) execute the final settlement
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agreement documents; 2) obtain approval from City of Oakland’s City Council; and 3) effectuate
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the disbursement of settlement moneys. The Parties believe they can resolve these pending issues
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within 60 days and hope to submit a stipulation for dismissal within that time period. A case
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management conference at this time would prove unhelpful for both the Parties and the Court in
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facilitating the resolution of this proceeding. Accordingly, the parties ask the Court to order that
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the April 3 conference be continued to May 22, 2015.
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IT IS SO STIPULATED.
16 Dated: March 19, 2015
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18 THE UKOHA-AJIKE LAW GROUP PC

HINSHAW & CULBERTSON LLP

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By: /s/ Endy Ukoha-Ajike
ENDY UKOHA-AJIKE
Attorneys for Plaintiff
21
Dessie R. Nelson
20

22

By: /s/ James A. Hazlehurst
MARTIN E. ROSEN
JAMES A. HAZLEHURST
Attorneys for Defendant Hartford Life
Insurance Company

23
24

MOORE & MOORE

25 By: /s/ Howard Moore, Jr.
HOWARD MOORE, JR.
26
Attorney for Third Party Defendant
Juliana James
27

MEYERS NAVE APLC
By: /s/ Emilie de la Motte
EMILIE E. DE LA MOTTE
Attorneys for Third Party Defendant
City of Oakland

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13-CV-04196-CRB
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STIPULATED REQUEST FOR CMC CONTINUANCE; [PROPOSED] ORDER

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ORDER
Now before the Court is the Parties request to continue the Case Management Conference

3 for forty-five (45) days. The parties submitted a joint stipulation, appearing above, which showed
4 good cause exists to continue the case management conference, so that the Parties may finalize the
5 terms of their respective settlement agreements. Having read and considered the arguments
6 submitted by the Parties, IT IS ORDERED THAT:
7

The April 3, 2015 Case Management Conference is hereby CONTINUED to May 22, 2015

8 at 8:30 a.m. in Department 6. All associated deadlines, including the submittal of a joint case

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DATED: March 20, 2015

By:

O ORD

IT IS S

The Honorable Charles R. BreyerR. Breyer
harles
Judge C
Senior District Court Judge
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ERED

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IT IS SO ORDERED.

UNIT
ED

10

ISTRIC
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9 management conference, shall accord with the new conference date.

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13-CV-04196-CRB
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STIPULATED REQUEST FOR CMC CONTINUANCE; [PROPOSED] ORDER