Travelers Property Casualty Company of America v., Inc.

Filing 22

ORDER by Judge Vince Chhabria granting AS MODIFIED 21 Stipulation postponing case management conference. Case Management Statement due by 4/14/2021. Initial Case Management Conference set for 4/21/2021 02:00 PM by Videoconference Only. (vclc2S, COURT STAFF) (Filed on 3/17/2021)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Mark D. Peterson (Cal. Bar # 126174) CATES PETERSON LLP 4100 Newport Place, Suite 230 Newport Beach, CA 92660 Telephone: (949) 724-1180 Facsimile: (949) 724-1190 E-mail: Attorneys for Plaintiff Travelers Property Casualty Company of America David B. Goodwin (Cal. Bar # 104469) Jeffrey M. Davidson (Cal. Bar # 248620) Hannah M. Chartoff (Cal. Bar # 324529) COVINGTON & BURLING LLP Salesforce Tower 415 Mission Street, Suite 5400 San Francisco, CA 94105-2533 Telephone: +1 (415) 591-6000 Facsimile: +1 (415) 955-6530 Email: Email: Email: Attorneys for Defendant, inc. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION 18 19 20 21 22 TRAVELERS PROPERTY CASUALTY COMPANY OF AMERICA, Plaintiff, 23 24 25 26 v. SALESFORCE.COM, INC., Case No. 3:20-cv-9443-VC Hon. Vince Chhabria STIPULATION REGARDING CASE SCHEDULE AND [PROPOSED] ORDER AS MODIFIED Defendant. 27 28 STIPULATION REGARDING CASE SCHEDULE AND [PROPOSED] ORDER CASE NO. 3:20-CV-9443-VC Pursuant to Civil L.R. 6-2(a) and this Court’s Civil Standing Order ¶ 14, 1 2 Plaintiff Travelers Property Casualty Company of America and Defendant, 3 inc. (collectively, the “Parties”) respectfully submit the following Stipulation Regarding 4 Case Schedule and [Proposed] Order. STIPULATION 5 6 7 8 9 10 11 WHEREAS, on January 4, 2021, Plaintiff served Defendant with a complaint in this action (Dkt. 7; see Dkt. 1); WHEREAS, following the Parties’ Stipulation Enlarging Time to Respond to Complaint (Dkt. 16), the Court ordered Defendant to respond to Plaintiff’s complaint by February 24, 2021 (Dkt. 17); WHEREAS, on February 24, 2021, Defendant filed a motion to dismiss Plaintiff’s 12 first claim for relief and a motion to stay Plaintiff’s remaining two claims for relief 13 (Dkt. 18); 14 15 16 17 18 19 20 21 22 WHEREAS, on March 10, 2021, Plaintiff filed an opposition to Defendant’s motions (Dkt. 19); WHEREAS, consistent with Federal Rule of Civil Procedure 26(f), counsel for Plaintiff and counsel for Defendant met and conferred on March 10, 2021; WHEREAS, the Court set an initial case management conference for March 31, 2021 (Dkt. 11); WHEREAS, the Court is scheduled to hear argument on Defendant’s motion to dismiss and motion to stay on April 1, 2021; WHEREAS, the Court’s ruling on Defendant’s motions to dismiss and to stay, if 23 granted, would effectively dispose of this case, in that Plaintiff’s first claim for relief 24 would be dismissed and its remaining claims would be indefinitely stayed, pending the 25 outcome of the underlying Texas state-court litigation and, if denied, would affect how the 26 case would proceed and what would remain for the parties to address; 27 28 THEREFORE, the Parties, by and through their respective undersigned counsel, hereby stipulate and agree to, and respectfully request that the Court order, that the initial 1 STIPULATION REGARDING CASE SCHEDULE AND [PROPOSED] ORDER CASE NO 3:20-cv-9443-VC

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