HDI Global Insurance Company v. Elizabeth Court LP, et al

Filing 23

STIPULATION AND ORDER as Modified re 22 Stipulation (1) Requesting the Continuance of the July 7, 2016 Motion Hearing Date and August 2, 2016 Further Telephonic Status Conference; and (2) Setting a Briefing Schedule for the Parties' Cross- Motions for Summary Judgment on HDI Global Ins. Co.'s Complaint, filed by HDI Global Insurance Company. Motions due by 6/23/2016. Cross Motions/Second Breif due by 7/7/2016. Third Brief due by 7/21/2016. Fourth Brief due by 8/4/2016. Motion Hearing re Cross Motions for Summary Judgment set for 8/18/2016 10:00 AM in Courtroom 4, 17th Floor, San Francisco before Hon. Vince Chhabria. Case Management Statement due by 9/6/2016. Further Case Management Conference set for 9/13/2016 02:30 PM in Courtroom 4, 17th Floor, San Francisco. Signed by Judge Vince Chhabria on 5/6/2016. (knm, COURT STAFF) (Filed on 5/6/2016)

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NEIL SELMAN(SBN 62720)
[e-mail]
MEKA MOORE(SBN 180017)
[e-mail]
JENNIFER REVITZ(SBN 229644)
[e-mail]
ELISABETH M.D'AGOSTINO(SBN 251179)
[e-mail]
SELMAN BREITMAN LLP
11766 Wilshire Blvd., Sixth Floor
Los Angeles, CA 90025-6538
Telephone: [phone]
Facsimile: 310.473.2525

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Attorneys for Plaintiff
9 HDI GLOBAL INSURANCE COMPANY
UNITED STATES DISTRICT COURT

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ATTORNEYS AT LAW

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NORTHERN DISTRICT OF CALIFORNIA

12 HDI GLOBAL INSURANCE COMPANY,an
Illinois corporation„
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Plaintiff,
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v.
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ELIZABETH COURT LP,a California limited
16 partnership; WASHINGTON SQUARE
ASSETS LLC; RUSSELL B. FLYNN; and
17 DOES 1-30, inclusive„

Case No. 16-cv-00210-VC
STIPULATION AND [PROPOSED]ORDER:
(1)REQUESTING THE CONTINUANCE OF
THE JULY 7, 2016 MOTION HEARING DATE
AND AUGUST 2, 2016 FURTHER
TELEPHONIC STATUS CONFERENCE; AND
(2)SETTING A BRIEFING SCHEDULE FOR
THE PARTIES' CROSS-MOTIONS FOR
SUMMARY JUDGMENT ON HDI GLOBAL
INSURANCE COMPANY'S COMPLAINT

AS MODIFIED
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Defendants.

Judge:

Hon. Vince Chhabria

Complaint Filed:

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January 13, 2016

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HDI GLOBAL INSURANCE COMPANY("HDI Global") and ELIZABETH COURT
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LP, by and through their attorneys of record, submit the instant stipulation and proposed order:
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Whereas, on April 12, 2016, the parties attended a Telephonic Case Management
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Conference, and the Court ordered that Cross Motions for Summary Judgment on Plaintiff HDI
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Global's claims be heard on July 7, 2016 at 10:00 a.m. Additionally, the Court scheduled a
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Further Telephonic Case Management Conference for August 2, 2016 at 2:30 p.m.
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Whereas, the parties have agreed to mediate this matter during June 2016, and are in the
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process of confirming the mediation date.
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STIPULATION AND[PROPOSED] ORDER SETTING A BRIEFING SCHEDULE
16-cv-00210-VC
690403.1 2664.37875

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Whereas,the parties discussed the timing of the mediation session and the motion hearing

2 scheduled for July 7, 2016, and agreed that the mediation session would be more fruitful if the
3 motion hearing date was continued to August 18, 2016, or a date thereafter as is convenient for
4 the Court.
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Whereas, the parties have agreed to a briefing schedule based on the proposed August 18,

6 2016 Cross Motion hearing date, as set forth below.
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THEREFORE,Plaintiff HDI Global and Defendant Elizabeth Court LP hereby stipulate

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• The Parties respectfully request that the hearing on the parties' Cross Motions for

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Summary Judgment on HDI Global's Complaint be continued from July 7, 2016 to

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August 18, 2016 at 10:00 a.m.;

ATTORNEYS AT LAW

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• The Parties also respectfully request that the Further Telephonic Case Management

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Conference be continued from August 2, 2016 to September 13, 2016 at 2:30 p.m.;

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• The Parties also agree to the following briefing schedule based on the proposed
August 18, 2016 hearing date:

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o Last Day to File HDI Global's Opening Brief: June 23, 2016

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o Last Day to File Elizabeth Court LP's Opening/Opposition Brief: July 7,
2016

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o Last Day to File HDI Global's Opposition/Reply Brief: July 21, 2016

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Last Day to File Elizabeth Court LP's Reply Brief: August 4, 2016

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22 DATED: May 5, 2016

SELMAN BREITMAN LLP

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By: /s/ Elisabeth M D'Agostino
MEKA MOORE
JENNIFER REVITZ
ELISABETH M.D'AGOSTINO
Attorneys for Plaintiff
HDI GLOBAL INSURANCE COMPANY

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STIPULATION AND[PROPOSED] ORDER SETTING A BRIEFING SCHEDULE
16-cv-00210-VC
690403.1 2664,37875

DATED: May 5, 2016

BRANSON,BRINKOP, GRIFFITH &
CAMPO,LLP

By: /s/John R. Campo
JOHN R. CAMPO
Attorneys for Defendant and Counter-Claimant
ELIZABETH COURT LP
The filer of this document attests that she obtained authority from Mr. Campo to affix his esignature hereto.

[PROPOSED] ORDER AS MODIFIED
PURSUANT TO STIPULATION,THE COURT ORDERS AS FOLLOWS:
(1) The hearing on the parties' Cross Motions for Summary Judgment on HDI Global's

ATTORNEYS AT LAW

Complaint is continued to August 18, 2016 at 10:00 a.m.;
(2) The Further Telephonic Case Management Conference is continued to September 13,
2016 at 2:30 p.m.;
(3) The Parties shall submit briefing related to the August 18, 2016 motion hearing
pursuant to the below briefing schedule:
o Last Day to File HDI Global's Opening Brief: June 23, 2016
o Last Day to File Elizabeth Court LP's Opening/Opposition Brief: July 7, 2016
o Last Day to File HDI Global's Opposition/Reply Brief: July 21, 2016
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Last Day to File Elizabeth Court LP's Reply Brief: August 4, 2016

***No further continuances will be granted.***

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Hon. Vince Chhabria IFIED
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Dated: May 6, 2016

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IT IS SO ORDERED.

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STIPULATION AND[PROPOSED]ORDER S T R I C BRIEFING SCHEDULE
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16-cv-00210-VC
690403.1 2664.37875