Pho Thanh Phat, Inc. v. Travelers Casualty Insurance Company of America

Filing 10

STIPULATION AND ORDER CONTINUING INITIAL CASE MANAGEMENT CONFERENCE: Re 9 Proposed Order filed by Travelers Casualty Insurance Company of America A Joint Case Management Statement due by 1/22/2015. Case Management Conference set for 1/29/2015 at 11:00 AM in Courtroom C, 15th Floor, San Francisco. Signed by Magistrate Judge Laurel Beeler on 11/13/2014. (lsS, COURT STAFF) (Filed on 11/13/2014)

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MARJIE D. BARROWS (State Bar No. 122129)
KATHLEEN M. DeLANEY (State Bar No. 196376)
FORAN GLENNON PALANDECH
PONZI & RUDLOFF PC
2000 Powell Street, Suite 900
Emeryville, CA 94608
Telephone:
[phone]
Facsimile:
[phone]

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Attorneys for Defendant TRAVELERS CASUALTY
INSURANCE COMPANY OF AMERICA

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ATTORNEYS AT LAW
2000 POWELL STREET, SUITE 900
EMERYVILLE, CALIFORNIA 94608
[phone]

FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

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PHO THANH PHAT, INC. dba PHO LEE
HOA PHAT,

3:14-CV-03822-LB
STIPULATION AND PROPOSED
ORDER TO CONTINUE INITIAL
CASE MANAGEMENT
CONFERENCE

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Plaintiff,
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vs.
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TRAVELERS CASUALTY INSURANCE
COMPANY OF AMERICA, AND DOES 1
TO 10,

Complaint filed: March 6, 2014
Trial Date:
Not Yet Set

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Defendants.
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/

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Defendant TRAVELERS CASUALTY INSURANCE COMPANY OF AMERICA

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(“Defendant” or “Travelers”) and Plaintiff PHO THANH PHAT, INC. dba PHO LEE HOA PHAT

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(“Plaintiff”), by and through their attorneys of record, stipulate as follows:

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1.

The Court has set an Initial Case Management Conference in this matter for

November 20, 2014.
2.

Counsel for Plaintiff has indicated that Plaintiff intends to amend its complaint in

this matter.
3.

In addition, the parties are interested in entering into confidential settlement

discussions in an attempt to informally resolve this matter.
4.

Therefore the parties request that the Initial Case Management Conference in this

matter be continued for at least sixty (60) days to allow the parties to attempt to informally resolve
-1STIPULATION AND PROPOSED ORDER TO CONTINUE INITIAL CMC
CASE NO. 3:14-CV-03822-LB

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this matter, and, if necessary, for Plaintiff to amend its complaint.
5.

There have been no prior requests for a continuance on this Case Management

Conference.
NOW, THEREFORE, by and through their undersigned counsel of record, Defendant

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TRAVELERS CASUALTY INSURANCE COMPANY OF AMERICA and Plaintiff PHO

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THANH PHAT, INC. dba PHO LEE HOA PHAT hereby stipulate to the following:

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from November 20, 2014 to January 29, 2014 at 11:00 a.m. in Courtroom C.

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2. The last day to file Rule 26(f) Report, complete initial disclosures or state objection in

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Rule 26(f) Report and file Case Management Statement shall be continued to January

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ATTORNEYS AT LAW
2000 POWELL STREET, SUITE 900
EMERYVILLE, CALIFORNIA 94608
[phone]

FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

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1. The date for the Initial Case Management Conference in this matter shall be continued

22, 2015.

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DATED: November 12, 2014

FORAN GLENNON PALANDECH
PONZI & RUDLOFF PC

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By:

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/s/ Marjie D. Barrows
Marjie D. Barrows
Kathleen M. DeLaney

Attorneys for Defendant TRAVELERS
CASUALTY INSURANCE COMPANY OF
AMERICA

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DATED: November 12, 2014

VU S.A. LAW OFFICES, APC
By:

/s/ Michael C. Vu
Michael Chinh Vu

Attorney for Plaintiff PHO THANH PHAT, INC.
dba PHO LEE HOA PHAT

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-2STIPULATION AND PROPOSED ORDER TO CONTINUE INITIAL CMC
CASE NO. 3:14-CV-03822-LB

[PROPOSED] ORDER

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1. The date for the Initial Case Management Conference in this matter is continued from
November 20, 2014 to January 29, 2014 at 11:00 a.m. in Courtroom C.

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2. The last day to file Rule 26(f) Report, complete initial disclosures or state objection in

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Rule 26(f) Report and file Case Management Statement is continued to January 22,

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2015.

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IT IS SO ORDERED.

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DATED: November ___, 2014

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ATTORNEYS AT LAW
2000 POWELL STREET, SUITE 900
EMERYVILLE, CALIFORNIA 94608
[phone]

FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

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By: : ______________________________
HON. LAUREL BEELER
U.S. DISTRICT JUDGE

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-3STIPULATION AND PROPOSED ORDER TO CONTINUE INITIAL CMC
CASE NO. 3:14-CV-03822-LB