Moon Mountain Farms, LLC v. Rural Community Insurance Company

Filing 27

STIPULATION AND ORDER Extending Time for Plaintiff to File Reply as to 1 MOTION to Compel. Replies due by 6/20/2014. Signed by Judge Samuel Conti on 06/17/2014. (tmi, COURT STAFF) (Filed on 6/17/2014)

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Carlyle (Cary) W. Hall III (CA BAR NO. 184842)
[e-mail]
Troy B. Froderman (AZ BAR NO. 012717) (Admitted pro hac vice)
[e-mail]
POLSINELLI PC
CityScape
One E. Washington St., Ste. 1200
Phoenix, AZ 85004
Phone: [phone]
Fax: [phone]
Richard Giller (CA BAR NO. 117823)
[e-mail]
POLSINELLI LLP
2049 Century Park East, Ste. 2300
Los Angeles, CA 90067
Phone: [phone]
Fax: [phone]
Attorneys for Plaintiff
IN THE UNITED STATES DISTRICT COURT

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FOR THE NORTHERN DISTRICT OF CALIFORNIA

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(SAN FRANCISCO DIVISION)

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MOON MOUNTAIN FARMS, LLC,

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Action pending in the United States
District Court for the District of Arizona
(2:13-CV-00349-SRB)

Plaintiff,

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Case No. 3:14-MC-80099-SC

vs.

STIPULATION AND [PROPOSED]
ORDER EXTENDING TIME FOR
PLAINTIFF TO FILE ITS REPLY
IN SUPPORT OF ITS MOTION TO
COMPEL

RURAL COMMUNITY INSURANCE
COMPANY,

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Defendant.

Judge:
Date:
Time:
Place:

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Hon. Samuel Conti
July 11, 2014
10:00 a.m.
Courtroom 1, 17th Floor

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STIPULATION TO EXTEND TIME TO FILE REPLY
IN SUPPORT OF MOTION TO COMPEL

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Pursuant to Northern District of California Civil Local Rules 6-1(b), 6-2 and 712, Plaintiff Moon Mountain Farms, LLC (“MMF”) and Non-Party Wells Fargo &

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Case No. 3:13-mc-80099-SC
Stipulation and [PROPOSED] Order Extending Time;
Declaration of Troy B. Froderman
48250716.2

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Company (“Wells Fargo”) (collectively the “Parties”), by and through their respective

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counsel, hereby stipulate to extend MMF’s Reply in Support of its Motion to Compel as

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follows:

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WHEREAS, the Parties who sign this Stipulation constitute all of the parties to
this proceeding;
WHEREAS, on April 4, 2014, MMF filed its Notice of Motion and Motion to
Compel Compliance with Subpoena;
WHEREAS, on May 30, 2014, Wells Fargo filed its Response to MMF’s Motion
to Compel Compliance with Subpoena;
WHEREAS, currently MMF’s Response was due Friday, June 13, 2014, and the
Motion is set to be heard on July 11, 2014, at 10:00 a.m.;

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WHEREAS, the Parties conferred on June 15th and 16th regarding MMF’s

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request for a brief extension of time to file its Reply in Support of its Motion to Compel;

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WHEREAS, the Parties agree to delaying MMF’s Reply due to the unexpected
death of MMF counsel’s near family member;

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WHEREAS, the Parties agree that this extension of time will not jeopardize the

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disposition of the Parties’ pending motions or the dates for the close of discovery, trial

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date and related deadlines of the underlying action, pending in the United States District

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Court for the District of Arizona (2:13-cv-00349-SRB);

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THE PARTIES DO HEREBY AGREE AND STIPULATE to the following:

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Plaintiff MMF shall have until Friday, June 20, 2014, to file its Reply in

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Support of its Motion to Compel.

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Dated: June 17, 2014

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Respectfully submitted,

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POLSINELLI PC

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By: s/Troy B. Froderman
Troy B. Froderman

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Case No. 3:13-mc-80099-SC
Stipulation and [PROPOSED] Order Extending Time;
Declaration of Troy B. Froderman
48250716.2

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Dated: June 16, 2014
Respectfully submitted,

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SHEPPARD, MULLIN, RICHTER & HAMPTON LLP

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By: s/Raymond C. Marshall (with permission)
Raymond C. Marshall

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Case No. 3:13-mc-80099-SC
Stipulation and [PROPOSED] Order Extending Time;
Declaration of Troy B. Froderman
48250716.2

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[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: June ___, 2014

Hon. Samuel Conti
United States District Judge
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Case No. 3:13-mc-80099-SC
Stipulation and [PROPOSED] Order Extending Time;
Declaration of Troy B. Froderman
48250716.2