Gonzales & Gonzales Bonds and Insurance Agency, Inc. v. United States Department of Homeland Security
Filing
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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:
(818) 992-9999
Facsimile:
(818) 992-9991
Email:
gan@rpnalaw.com, drg@rpnalaw.com
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: (415) 436-6813
FAX: (415) 436-6748
annie.reding@usdoj.gov
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
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