Titan Indemnity Company v. A Plus Towing, et al

Filing 54

ORDER GRANTING 53 STIPULATION TO CONTINUE HEARING DATE OF PLAINTIFF TITAN INDEMNITY COMPANYS MOTION FOR SUMMARY JUDGMENT.(whalc2, COURT STAFF) (Filed on 8/11/2015)

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MARTIN T. REILLEY, ESQ. (SBN 83697)
KRANKEMANN | PETERSEN LLP
Attorneys At Law
375 E Street, Suite 120
Santa Rosa, California 95404
Telephone: [phone]
Facsimile: [phone]
Attorney for Defendant
KATRINA RAPP

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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TITAN INDEMNITY COMPANY, a Texas
corporation,

CASE NO.: C 14-03864 WHA

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STIPULATION TO CONTINUE HEARING
DATE OF PLAINTIFF TITAN INDEMNITY
COMPANY’S MOTION FOR SUMMARY
JUDGMENT AND [PROPOSED] ORDER

Plaintiff,
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vs.
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A PLUS TOWING, a General Partnership;
JOSE HERMOSILLO, individually and dba A
PLUS TOWING; FERNANDO
HERMOSILLO, individually and dba A PLUS
TOWING; A PLUS TOWING, a business
organization form unknown, and KATRINA
RAPP, an individual, and DOES 1-10,

Date:
Time:
Judge:
Dept.:

September 3, 2015
8:00 a.m.
Hon. William Alsup
Courtroom 8, 19th Floor

Complaint Filed:

August 26, 2014

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Defendants.
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-1STIPULATION TO CONTINUE HEARING DATE OF PLAINTIFF TITAN INDEMNITY COMPANY’S
MOTION FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER

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Plaintiff Titan Indemnity Company (“Titan”) and Defendant Katrina Rapp, (“Defendant
Rapp”) hereby stipulates as follows:
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The hearing on Titan’s Motion for Summary Judgment is currently schedule for

September 3, 2015 at 8:00 a.m.
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On July 30, 2015, Titan filed its Notice of Motion and Motion for Summary

Judgment.
3.

On July 31, 2015, Defendant Rapp promptly contacted Titan and asked if Titan

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would be willing to continue the hearing in order to extend Defendant Rapp’s response presently

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due on August 13, 2015. Defendant Rapp’s counsel is schedule to leave on a long planned family

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vacation on August 7, 2015 and will not be returning to the office until August 24, 2015.

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4.

On August 3, 2015, Titan agreed to continue the hearing until September 17, 2015.

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5.

In light of the foregoing, the parties respectfully request that the hearing on the

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Motion for Summary Judgment be continued to September 17, 2015 at 8:00 a.m. and that all

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associated deadlines be continued accordingly.

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IT IS SO STIPULATED.
DATED: August 5, 2015

Respectfully submitted,

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KRANKEMANN | PETERSEN LLP

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By: ___/s/ Martin Reilley___________________
MARTIN T. REILLEY
Attorney for Defendant
KATRINA RAPP

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SELMAN BREITMAN LLP

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By: ___/s/ Galina Klester Jakobson__________
GALINA KLESTER JAKOBSON
QUYEN THI LE
Attorneys for Plaintiff
TITAN INDEMNITY COMPANY

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-2STIPULATION TO CONTINUE HEARING DATE OF PLAINTIFF TITAN INDEMNITY COMPANY’S
MOTION FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER

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[PROPOSED] ORDER

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Pursuant to stipulation of the parties, and good cause appearing therefore, it is hereby

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ordered that:
1.

The date for Plaintiff Titan Indemnity Company’s hearing on the Motion for

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Summary Judgment has been continued from September 3, 2015 to September 17, 2015 at

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8:00 a.m.

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2.

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All deadlines associated with the Motion shall be continued accordingly.

IT IS SO ORDERED.

Plaintiff's opposition is now due on August 27, 2015. Defendant's
reply is due on September 3, 2015.

August 11, 2015.
Dated: ______________________

__________________________________
Hon. William Alsup
United States District Judge

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-3-

STIPULATION TO CONTINUE HEARING DATE OF PLAINTIFF TITAN INDEMNITY COMPANY’S
MOTION FOR SUMMARY JUDGMENT AND [PROPOSED] ORDER