Nelson v. Hartford Life Insurance Company

Filing 91

ORDER, granting 90 STIPULATION WITH PROPOSED ORDER (Re Requested Continuance of CMC) filed by City Of Oakland. Supplemental Case Management Statement due by 7/10/2015. Further Case Management Conference reset for 7/17/2015 08:30 AM. Signed by Judge Charles R. Breyer on 5/18/2015. (beS, COURT STAFF) (Filed on 5/18/2015)

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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EXEMPT FROM FILING FEES
GOV’T CODE § 6103

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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,
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Third-Party Defendants.
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CITY OF OAKLAND,
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Cross-Claimant,
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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 May 22,
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 agreed to settle all claims and cross-claims alleged in
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this lawsuit. The terms of the agreements have already been agreed upon by the Parties and their
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counsel. The Parties need, however, additional time to: 1) execute the final settlement agreement
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documents; and 2) effectuate the disbursement of settlement moneys. Oakland City Council has
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approved settlement and the City Attorney’s Office has requested the issuance of a settlement
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check, which should be received within the next 4-5 days. The Parties believe they can resolve
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these pending issues within 45 days and hope to submit a stipulation for dismissal within that time
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period. A case management conference at this time would prove unhelpful for both the Parties
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and the Court in facilitating the resolution of this proceeding. Accordingly, the parties ask the
15 Court to order that the May 22 conference be continued to July 10, 2015.
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IT IS SO STIPULATED.

17 Dated: May 14, 2015
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19 THE UKOHA-AJIKE LAW GROUP PC

HINSHAW & CULBERTSON LLP

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By: /s/ Endy Ukoha-Ajike
ENDY UKOHA-AJIKE
Attorneys for Plaintiff
22
Dessie R. Nelson
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By: /s/ James A. Hazlehurst
MARTIN E. ROSEN
JAMES A. HAZLEHURST
Attorneys for Defendant Hartford Life
Insurance Company

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24
MOORE & MOORE

MEYERS NAVE APLC

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26 By: /s/ Howard Moore, Jr.
HOWARD MOORE, JR.
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Attorney for Third Party Defendant
Juliana James
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By: /s/ Emilie de la Motte
EMILIE E. DE LA MOTTE
Attorneys for Third Party Defendant
City of Oakland

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:
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The May 22, 2015 Case Management Conference is hereby CONTINUED to July 17, 2015

8 at 8:30 a.m. in Department 6. All associated deadlines, including the submittal of a joint case
9 management conference, shall accord with the new conference date.
IT IS SO ORDERED.

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The Honorable Charles R. Breyer
Senior District CourtRDERED
Judge

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By:

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DATED: May, 18, 2015
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13-CV-04196-CRB
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STIPULATED REQUEST FOR CMC CONTINUANCE; [PROPOSED] ORDER