Mendocino Wine Group, LLC v. QBE Americas, Inc. et al

Filing 41

ORDER by Judge Haywood S. Gilliam, Jr. Granting 40 Stipulation to Continue Deadlines to Respond and Reply to Defendant Unigard Insurance Company's 39 Motion to Dismiss Plaintiff's 38 First Amended Complaint filed by Mendocino Wine Group, LLC. (ndrS, COURT STAFF) (Filed on 9/15/2016)

1
2
3
4

LAW OFFICES OF

WALKUP, MELODIA, KELLY & SCHOENBERGER
A PROFESSIONAL CORPORATION

650 CALIFORNIA STREET, 26TH FLOOR
SAN FRANCISCO, CALIFORNIA 94108-2615
[phone]

6

KHALDOUN A. BAGHDADI (SB 190111)
[e-mail]
VALERIE N. ROSE (State Bar #272566)
[e-mail]

7

MENDOCINO WINE GROUP, LLC

5

ATTORNEYS FOR PLAINTIFF

8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10
11

MENDOCINO WINE GROUP, LLC,

12

Plaintiff,

13

v.

14

UNIGARD INSURANCE COMPANY, QBE
AMERICAS, INC., and DOES 1-50,

Case No. 3:15-cv-06342-HSG
JOINT STIPULATION AND ORDER TO
CONTINUE DEADLINES TO RESPOND
AND REPLY TO DEFENDANT UNIGARD
INSURANCE COMPANY’S MOTION TO
DISMISS PLAINTIFF’S FIRST
AMENDED COMPLAINT

15
Defendants.
16
17

TO THE COURT, ALL PARTIES, AND THEIR ATTORNEYS OF RECORD:

18

Whereas, the parties have met and conferred regarding their schedules;

19

Whereas, there is a motion to dismiss under submission;

20

Whereas, plaintiff’s counsel will be starting trial on September 21, 2016 in Dallas;

21

Whereas, the parties agree and respectfully suggest that an extension of time for both sides

22

to respond and reply would make sense for counsel and their clients;

23

In light of the foregoing, and given that the hearing on this motion is set for November 17,

24

2016, the parties stipulate and respectfully request that the deadline for the plaintiff’s response be

25

continued from September 23, 2016 to September 30, 2016, and that the deadline for defendant’s

26

reply be continued from September 30, 2016 to October 7, 2016.

27
28
JOINT STIPULATION AND ORDER TO CONTINUE DEADLINES TO RESPOND AND REPLY TO DEFENDANT
UNIGARD INSURANCE COMPANY’S MOTION TO DISMISS PLAINTIFF’S FIRST AMENDED COMPLAINT - CASE NO.
3:15-CV-06342-HSG

1

Respectfully submitted,

2
Dated: September 14, 2016

WALKUP , M ELODIA , K ELLY & S CHOENBERGER

3
4
/s/ Khaldoun A. Baghdadi
KHALDOUN A. BAGHDADI
Attorneys for Plaintiff MENDOCINO WINE GROUP,
LLC

5
6
7
8

Dated: September 14, 2016

S ELVIN WRAITH H ALMAN , LLP

9
/s/ Gary R. Selvin
GARY R. SELVIN
Attorneys for Defendants UNIGARD INSURANCE
COMPANY, QBE AMERICAS, INC.

10
11
12
13
14
15

ORDER TO CONTINUE DEADLINES TO RESPOND AND REPLY
TO DEFENDANT UNIGARD INSURANCE COMPANY’S MOTION
TO DISMISS PLAINTIFF’S FIRST AMENDED COMPLAINT

16
The parties’ stipulation is adopted and IT IS SO ORDERED. The deadline for the
17
plaintiff’s response is continued from September 23, 2016 to September 30, 2016, and that the
18
deadline for defendant’s reply is continued from September 30, 2016 to October 7, 2016.
19
20
Dated: September 15, 2016
21
22
23

HON. HAYWOOD S. GILLIAM, JR.
United States District Court Judge

24
25
26
27
28
LAW OFFICES OF

WALKUP, MELODIA, KELLY
& SCHOENBERGER
A PROFESSIONAL CORPORATION

650 CALIFORNIA STREET
26TH FLOOR
SAN FRANCISCO, CA 94108
[phone]

2
JOINT STIPULATION AND ORDER TO CONTINUE DEADLINES TO RESPOND AND REPLY TO DEFENDANT
UNIGARD INSURANCE COMPANY’S MOTION TO DISMISS PLAINTIFF’S FIRST AMENDED COMPLAINT - CASE NO.
3:15-CV-06342-HSG