Travelers Property Casualty Company of America v. Salesforce.com, 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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Mark D. Peterson (Cal. Bar # 126174)
CATES PETERSON LLP
4100 Newport Place, Suite 230
Newport Beach, CA 92660
Telephone: [phone]
Facsimile: [phone]
E-mail: [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: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendant
salesforce.com, inc.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
SAN FRANCISCO DIVISION

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TRAVELERS PROPERTY
CASUALTY COMPANY OF
AMERICA,
Plaintiff,

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v.
SALESFORCE.COM, INC.,

Case No. 3:20-cv-9443-VC
Hon. Vince Chhabria
STIPULATION REGARDING CASE
SCHEDULE AND [PROPOSED] ORDER
AS MODIFIED

Defendant.

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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,

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Plaintiff Travelers Property Casualty Company of America and Defendant salesforce.com,

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inc. (collectively, the “Parties”) respectfully submit the following Stipulation Regarding

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Case Schedule and [Proposed] Order.
STIPULATION

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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

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first claim for relief and a motion to stay Plaintiff’s remaining two claims for relief

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(Dkt. 18);

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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

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granted, would effectively dispose of this case, in that Plaintiff’s first claim for relief

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would be dismissed and its remaining claims would be indefinitely stayed, pending the

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outcome of the underlying Texas state-court litigation and, if denied, would affect how the

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case would proceed and what would remain for the parties to address;

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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
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STIPULATION REGARDING CASE SCHEDULE AND [PROPOSED] ORDER
CASE NO 3:20-cv-9443-VC