Continental Casualty Company v. Recology Inc.

Filing 20

ORDER, Motions terminated: 17 STIPULATION WITH PROPOSED ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE PURSUANT TO CIVIL LOCAL RULES 16-2(e) AND 7-12 filed by Recology Inc.. Initial Case Management Conference set for 12/18/2015 02:30 PM in Courtroom 10, 19th Floor, San Francisco.. Signed by Judge Susan Illston on 10/20/15. (tfS, COURT STAFF) (Filed on 10/20/2015)

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Nicholas P. Roxborough, Esq. (SBN 113540)
[e-mail]
Burton E. Falk, Esq. (SBN 100644)
[e-mail]
Charles R. Rondeau (SBN 164136)
[e-mail]
ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP
5820 Canoga Ave., Ste. 250
Woodland Hills, CA91367
Tel: [phone]
Fax: [phone]

Attorneys for Defendant
RECOLOGY, INC., f/k/a
8 NORCAL WASTE SYSTEMS, INC.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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Plaintiff,
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vs.
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RECOLOGY, INC., f/k/a NORCAL
WASTE SYSTEMS, INC., a California )
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corporation,
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Defendants.
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CASE NO. 3:15-cv-03969-SI

CONTINENTAL CASUALTY
COMPANY, an Illinois corporation,

Complaint filed on August 31, 2015
STIPULATION TO CONTINUE
CASE MANAGEMENT
CONFERENCE PURSUANT TO
CIVIL LOCAL RULES 16-2(e)
AND 7-12; [PROPOSED] ORDER
THEREON
CURRENT
Hearing Date: December 4, 2015
Time:
2:30 p.m.
Courtroom:
10
NEW
Hearing Date: December 18, 2015
Time:
2:30 p.m.
Courtroom:
10

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
THEREON

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TO THE COURT, ALL INTERESTED PARTIES AND THEIR COUNSEL
OF RECORD:
WHEREAS, the original Case Management Conference (“CMC”) was set by
the Court for Friday, December 4, 2015 at 2:30 p.m.;
WHEREAS, Defendant Recology, Inc., f/k/a Norcal Waste Systems, Inc.’s

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(“Defendant”) lead trial counsel Nick Roxborough recently discovered that he would

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be out of town on December 4, 2015 for business-related purposes for a meeting that

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could not be rescheduled;

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WHEREAS, Plaintiff Continental Casualty Company’s (“Plaintiff”) lead trial
counsel G. David Godwin is unavailable on December 11, 2015;
WHEREAS, the first date upon which both parties’ lead trial counsel will be
available is therefore December 18, 2015;

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WHEREAS, the parties are already engaging in an informal exchange of

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documents in preparation for a proposed early mediation date, and good cause exists

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for the requested continuance of the CMC; and

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WHEREAS, Defendant’s counsel checked Judge Illston’s online calendar and
did not find any conflict or unavailability for the Court on December 18, 2015.
NOW, THEREFORE, IT IS HEREBY STIPULATED that the CMC shall be
continued from December 4, 2015 to December 18, 2015 at 2:30 p.m.

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DATED: October 19, 2015

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RESPECTFULLY SUBMITTED,

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ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP

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By: /s/ Burton E. Falk
NICHOLAS P. ROXBOROUGH
BURTON E. FALK
CHARLES R. RONDEAU
Attorneys for Defendant RECOLOGY, INC.,
f/k/a NORCAL WASTE SYSTEMS, INC.

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
THEREON

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CARROLL, BURDICK & MCDONOUGH

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By: /s/ Geoffrey David Godwin
GEOFFREY DAVID GODWIN
Attorneys for Plaintiff
CONTINENTAL CASUALTY COMPANY,
an Illinois corporation

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
THEREON

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATE:

10/20/15

By:
THE HONORABLE SUSAN ILLSTON

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STIPULATION TO CONTINUE CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER
THEREON