Gonzales & Gonzales Bonds and Insurance Agency, Inc. v. United States Department of Homeland Security

Filing 26

ORDER re 25 Stipulation filed by United States Department of Homeland Security. Case Management Statement due by 2/2/2012. Motions due by 1/5/2012. Replies due by 1/26/2012. Responses due by 1/19/2012. Further Case Management Conference set for 2/9/2012 11:00 AM. Motion Hearing set for 2/9/2012 11:00 AM before Magistrate Judge Donna M. Ryu. Signed by Magistrate Judge Donna M. Ryu on 12/15/2011. (dmrlc2, COURT STAFF) (Filed on 12/15/2011)

Case4:11-cv-02267-DMR Document25

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Filed12/15/11 Page1 of 4

Gary A. Nye, Esq. (Cal. Bar No. 126104)
David R. Ginsburg, Esq. (Cal. Bar No. 210900)
ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP
5820 Canoga Avenue, Suite 250
Woodland Hills, California 91367
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail], [e-mail]
Attorneys for Plaintiff
GONZALES & GONZALES BONDS AND
INSURANCE AGENCY, INC.

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MELINDA HAAG (CSBN 132612)
United States Attorney

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JOANN M. SWANSON (CSBN 88143)
Chief, Civil Division

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ILA C. DEISS (NYSBN 3052909)
Assistant United States Attorney

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ANN MARIE REDING (CSBN 226864)
Assistant United States Attorney
450 Golden Gate Avenue, Box 36055
San Francisco, California 94102-3495
Telephone: [phone]
FAX: [phone]
[e-mail]
Attorneys for Defendant
UNITED STATES DEPARTMENT
OF HOMELAND SECURITY

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA - OAKLAND DIVISION

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GONZALES & GONZALES BONDS AND ) Case No. C 11-02267 DMR (LB)
)
INSURANCE AGENCY, INC.,
)
) JOINT STIPULATION AND [PROPOSED]
Plaintiff,
) ORDER CONTINUING THE HEARING ON
) DEFENDANT’S MOTION TO DISMISS
) AND CASE MANAGEMENT
vs.
) CONFERENCE
)
UNITED STATES DEPARTMENT OF
)
HOMELAND SECURITY,
)
)
)
Defendant.
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STIPULATION TO CONTINUE HEARING AND CASE MANAGEMENT CONFERENCE
C 11-02267 DMR

Case4:11-cv-02267-DMR Document25

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Filed12/15/11 Page2 of 4

STIPULATION
Plaintiff Gonzales & Gonzales Bonds and Insurance Agency, Inc. (“Plaintiff” or “G&G”)

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and Defendant United States Department of Homeland Security (“Defendant”), by and through

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their counsel of record, hereby stipulate and agree as follows:

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1.

Defendant’s motion to dismiss is currently scheduled for hearing on January 26,

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2012. On December 2, 2011, Defendant advised Plaintiff that it intended to amend its motion to

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dismiss by December 22, 2011. Defendant also advised that it would be amenable to continuing

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the hearing and filing deadlines so that the briefing schedule would not fall on or during the

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holidays.

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2.

Subject to the Court’s approval, and in order to avoid a briefing schedule falling

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during the holidays, the parties hereby agree and stipulate to the following briefing schedule for

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the motion to dismiss:

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Filing of amended motion:

January 5, 2012

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Opposition due:

January 19, 2012

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Reply due:

January 26, 2012

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Hearing:

February 9, 2012 at 11:00 a.m.

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The parties further agree that, subject to the Court’s approval, the Case Management

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Conference will be continued from January 26, 2012 to February 9, 2012, following the hearing

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on the motion to dismiss. The parties will file an updated Joint Case Management Conference

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Statement on or before February 2, 2012.

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3.

The hearing date has been continued once before when the parties participated in a

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Mandatory Settlement Conference with Magistrate Judge Laurel Beeler, and the parties sought a

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continuance in order to continue their efforts to seek a resolution in this case.

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4.

The parties believe that the requested continuance will have little, if any, impact on

the schedule for the case.

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STIPULATION TO CONTINUE HEARING AND CASE MANAGEMENT CONFERENCE
C 11-02267 DMR

Case4:11-cv-02267-DMR Document25

Filed12/15/11 Page3 of 4

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IT IS SO STIPULATED.

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Respectfully submitted,
MELINDA HAAG
United States Attorney

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Dated: December 15, 2011

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Respectfully submitted,
ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP

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/s/ Ann Marie Reding
ANN MARIE REDING
Assistant United States Attorney
Attorneys for the United States of America

Dated: December 15, 2011

/s/ David R. Ginsburg
GARY A. NYE
DAVID R. GINSBURG
Attorneys for Plaintiff
Gonzales & Gonzales Bonds
and Insurance Agency, Inc.

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STIPULATION TO CONTINUE HEARING AND CASE MANAGEMENT CONFERENCE
C 11-02267 DMR

Case4:11-cv-02267-DMR Document25

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Filed12/15/11 Page4 of 4

[PROPOSED] ORDER

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Pursuant to the stipulation by the parties, and good cause having been shown, it is hereby

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ordered that the following schedule will apply to Defendant’s amended motion to dismiss

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Plaintiff’s Complaint:

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Filing of amended motion:

January 5, 2012

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Opposition due:

January 19, 2012

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Reply due:

January 26, 2012

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Hearing:

February 9, 2012 at 11:00 a.m.

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A case Management Conference will take place following the hearing on the motion to

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dismiss. The parties will file an updated Joint Case Management Conference Statement on or

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before February 2, 2012.

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IT IS SO ORDERED.

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Dated:

December 15, 2011

_______________________________________
THE HONORABLE DONNA M. RYU
UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO CONTINUE HEARING AND CASE MANAGEMENT CONFERENCE
C 11-02267 DMR