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

Filing 24

STIPULATION AND ORDER TO CONTINUE DATE FOR FILING MOVING PAPERS FOR DISPOSITIVE MOTIONS re 22 Stipulation filed by Travelers Indemnity Company of Connecticut. Signed by Judge Patricia V. Trumbull on August 9, 2010. (pvtlc2, COURT STAFF) (Filed on 8/9/2010)

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

Doc. 24

1 2 3 4 5 6 7 8
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

9 10 11
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 DATE FOR FILING MOVING PAPERS FOR DISPOSITIVE MOTIONS; [PROPOSED] ORDER THEREON

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

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 extend the time for Travelers to file a motion for summary judgment, without changing the hearing date or any other dates for filing opposition or reply papers, 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, Travelers has been -1STIPULATION AND ORDER TO CONTINUE, CASE NO. C09-04144 PVT
Dockets.Justia.com

1 2 3 4 5 6 7 8
FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

prevented from meeting the existing August 10, 2010 deadline for filing its motion for summary judgment; and 2. This will not affect the last day for hearing dispositive motions 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 file and serve its motion for summary judgment shall

9 10 11
ATTORNEYS AT LAW 2000 POWELL STREET, SUITE 900 EMERYVILLE, CALIFORNIA 94608 [phone]

be August 17, 2010; 2. The last day for Plaintiff to file and serve its opposition to Travelers' motion for

summary judgment shall be August 24, 2010; 3. The last day for Travelers to file and serve its reply papers in support of its motion

12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 //

for summary judgment shall be August 31, 2010; and 4. The last day for a hearing on dispositive motions shall remain September 14, 2010. Respectfully submitted, DATED: August 6, 2010 FORAN GLENNON PALANDECH PONZI & RUDLOFF PC By: __/s/ Marjie D. Barrows Marjie D. Barrows __________

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

DATED: August 6, 2010

WILLIAMS, PINELLI & CULLEN, LLP By: __/s/ Amy Carlson Amy Carlson Attorneys for Plaintiff MICHEL FAMILY TRUST __________

-2STIPULATION AND ORDER TO CONTINUE, CASE NO. C09-04144 PVT

1 2 3 4 5 6 7 8
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 file and serve its motion for summary judgment shall

be August 17, 2010; 2. The last day for Plaintiff to file and serve its opposition to Travelers' motion for

summary judgment shall be August 24, 2010; 3. The last day for Travelers to file and serve its reply papers in support of its motion

for summary judgment shall be August 31, 2010 ; and 4. Date: The last day for a hearing on dispositive motions shall remain September 14, 2010. _________________________________ PATRICIA V. TRUMBULL UNITED STATES MAGISTRATE JUDGE

9 10 11
ATTORNEYS AT LAW 2000 POWELL STREET, SUITE 900 EMERYVILLE, CALIFORNIA 94608 [phone]

August 9, 2010

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