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

Filing 27

STIPULATION AND ORDER TO SUBMIT JOINT STATEMENT OF UNDISPUTED FACTS WITH MOTION FOR SUMMARY JUDGMENT AND REQUEST TO ALLOW THE MOTION TO EXCEED 25 PAGES re 26 Stipulation, filed by Travelers Indemnity Company of Connecticut. Signed by Judge Patricia V. Trumbull on August 12, 2010. (pvtlc2, COURT STAFF) (Filed on 8/12/2010)

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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 Defendant TRAVELERS INDEMNITY COMPANY OF CONNECTICUT 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 SUBMIT JOINT STATEMENT OF UNDISPUTED FACTS WITH MOTION FOR SUMMARY JUDGMENT AND REQUEST TO ALLOW THE MOTION TO EXCEED 25 PAGES;
XXXXXXXXXXX [PROPOSED] ORDER THEREON

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TO THE HONORABLE PATRICIA V. TRUMBULL, U.S. DISTRICT COURT MAGISTRATE JUDGE: STIPULATION WHEREAS, Plaintiff MICHEL FAMILY TRUST and Defendant TRAVELERS INDEMNITY COMPANY OF CONNECTICUT ("Travelers") have met and conferred and have agreed that certain facts in this litigation are undisputed and certain documents have been authenticated and are admissible as evidence, for purposes of Travelers' Motion for Summary Judgment only; NOW, THEREFORE, by and through their undersigned counsel of record, Plaintiff MICHEL FAMILY TRUST and Defendant TRAVELERS INDEMNITY COMPANY OF -1STIPULATION AND ORDER RE MSJ, CASE NO. C09-04144 PVT

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FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

CONNECTICUT hereby stipulate that, pursuant to Local Rule 56-2, the parties be allowed to file a Joint Statement of Undisputed Facts, with Exhibits, for use in supporting and opposing Travelers' Motion for Summary Judgment. REQUEST BY TRAVELERS TO EXCEED 25-PAGE LIMIT Because the undisputed facts in this matter are lengthy, Travelers respectfully requests that the Court permit it to file a motion for summary judgment that exceeds the 25-page limit set by Local Rule 7-2 by no more than seven pages, such that the motion shall be no longer than 32 pages.

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

Respectfully submitted, DATED: August 11, 2010 FORAN GLENNON PALANDECH PONZI & RUDLOFF PC By: __/s/ Kathleen M. DeLaney Kathleen M. DeLaney __________

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Attorneys for Defendant TRAVELERS INDEMNITY COMPANY OF CONNECTICUT

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

-2STIPULATION AND ORDER RE MSJ, CASE NO. C09-04144 PVT

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FORAN GLENNON PALANDECH PONZI & RUDLOFF PC

ORDER IT IS HEREBY ORDERED, pursuant to the Stipulation of the parties, that on or before August 17, 2010, the parties may file a Joint Statement of Undisputed Facts, with Exhibits, for use in supporting and opposing Travelers' Motion for Summary Judgment. IT IS FURTHER ORDERED that Travelers' Motion for Summary Judgment may be up to 32 pages in length. Date:
August 12, 2010

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

_________________________________ PATRICIA V. TRUMBULL UNITED STATES MAGISTRATE JUDGE

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