The Michel Family Trust v. Travelers Indemnity Company of Conneticut et al

Filing 21

STIPULATION AND ORDER TO CONTINUE DEFENDANTS' DESIGNATION OF EXPERTS AND HEARING DATE FOR DISPOSITIVE MOTIONS re 20 Stipulation filed by The Travelers Indemnity Company. Signed by Judge Patricia V. Trumbull on July 12, 2010. (pvtlc2, COURT STAFF) (Filed on 7/12/2010)

The Michel Family Trust v. Travelers Indemnity Company of Conneticut et al

Doc. 21

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FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

MARJIE D. BARROWS (SBN 122129) KATHLEEN M. DELANEY (SBN 196376) FORAN GLENNON PALANDECH PONZI & RUDLOFF PC 2000 Powell Street, Suite 900 Emeryville, CA 94608 Telephone: [phone] Facsimile: [phone] E-mail: [e-mail] [e-mail] Attorneys for Defendants TRAVELERS INDEMNITY COMPANY OF CONNECTICUT and THE TRAVELERS INDEMNITY COMPANY UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

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ATTORNEYS AT LAW 2000 POWELL STREET, SUITE 900 EMERYVILLE, CALIFORNIA 94608 [phone]

THE MICHEL FAMILY TRUST, Plaintiff, vs. TRAVELERS INDEMNITY COMPANY OF CONNECTICUT, THE TRAVELERS INDEMNITY COMPANY, and DOES 1 to 100, inclusive, Defendants.

CASE NO. C09-04144 PVT STIPULATION TO CONTINUE DEFENDANTS' DESIGNATION OF EXPERTS AND HEARING DATE FOR DISPOSITIVE MOTIONS; [PROPOSED] ORDER THEREON XXXXXXXXXXXXX

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TO THE HONORABLE PATRICIA V. TRUMBULL, U.S. DISTRICT COURT MAGISTRATE JUDGE: STIPULATION WHEREAS, Plaintiff MICHEL FAMILY TRUST and Defendants TRAVELERS INDEMNITY COMPANY OF CONNECTICUT and THE TRAVELERS INDEMNITY COMPANY ("Travelers") desire to continue (1) Travelers' designation of expert witnesses, and (2) the last day to have dispositive motions heard, on the following grounds: 1. Counsel for both parties have diligently worked to schedule percipient depositions,

but because of delays in document productions and scheduling depositions, counsel find that they

-1STIPULATION AND ORDER TO CONTINUE, CASE NO. C09-04144 PVT
Dockets.Justia.com

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FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

cannot meet the existing deadlines for Travelers' designation of expert witnesses and the dispositive motion hearing cut-off; and 2. This would be the first continuance in this matter.

NOW, THEREFORE, by and through their undersigned counsel of record, Plaintiff MICHEL FAMILY TRUST and Defendants TRAVELERS INDEMNITY COMPANY OF CONNECTICUT and THE TRAVELERS INDEMNITY COMPANY hereby stipulate to the following: 1. The last day for Travelers to designate expert witnesses with reports is

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ATTORNEYS AT LAW 2000 POWELL STREET, SUITE 900 EMERYVILLE, CALIFORNIA 94608 [phone]

continued to August 13, 2010; and 2. September 14, 2010. The last day for a hearing on dispositive motions is continued to

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 // // // -2STIPULATION AND ORDER TO CONTINUE, CASE NO. C09-04144 PVT By: __/s/ Amy Carlson Amy Carlson Attorneys for Plaintiff MICHEL FAMILY TRUST __________ DATED: July 6, 2010 WILLIAMS, PINELLI & CULLEN, LLP DATED: July 6, 2010 Respectfully submitted, FORAN GLENNON PALANDECH PONZI & RUDLOFF PC By: __/s/ Kathleen M. DeLaney Kathleen M. DeLaney __________

Attorneys for Defendants TRAVELERS INDEMNITY COMPANY OF CONNECTICUT and THE TRAVELERS INDEMNITY COMPANY

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FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

ORDER IT IS HEREBY ORDERED, pursuant to the Stipulation of the parties, as follows: 1. The last day for Travelers to designate expert witnesses with reports is continued to

August 13, 2010; and 2. 2010. Date:
July 12, 2010

The last day for a hearing on dispositive motions is continued to September 14,

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ATTORNEYS AT LAW 2000 POWELL STREET, SUITE 900 EMERYVILLE, CALIFORNIA 94608 [phone]

_________________________________ PATRICIA V. TRUMBULL UNITED STATES MAGISTRATE JUDGE

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 -3STIPULATION AND ORDER TO CONTINUE, CASE NO. C09-04144 PVT