Marble Bridge Funding Group, Inc v. Euler Hermes American Credit Indemnity Company

Filing 71

ORDER TO RESCHEDULE CASE MANAGEMENT CONFERENCE re 70 Order on Stipulation. Joint Case Management Statement due by 6/21/2013. Case Management Conference set for 6/28/2013 10:00 AM in Courtroom 4, 5th Floor, San Jose before Hon. Edward J. Davila. ***5/3/2013 CMC Deadlines terminated. Signed by Judge Edward J. Davila on 4/30/2013. (ecg, COURT STAFF) (Filed on 4/30/2013)

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BUCHALTER NEMER
A Professional Corporation
DENISE H. FIELD (SBN: 111532)
RANDALL L. MANVITZ (SBN: 224598)
55 Second Street, Suite 1700
San Francisco, CA 94105-3493
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]

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Attorneys for Plaintiff and Counter-Claim Defendant
MARBLE BRIDGE FUNDING GROUP, INC.

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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SAN JOSE DIVISION

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MARBLE BRIDGE FUNDING GROUP,
INC.,
Plaintiff,

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vs.

Case Nos.: 5:12-CV-01839-EJD; 5:12-CV02729-EJD

XXXXXXXX
STIPULATION AND [PROPOSED]
ORDER TO RESCHEDULE CASE
MANAGEMENT CONFERENCE

NATURE’S OWN PHARMACY, LLC, et
al.,

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Defendants.

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MARBLE BRIDGE FUNDING GROUP,
INC.,

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Plaintiff,

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vs.

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EULER HERMES AMERICAN CREDIT
INDEMNITY COMPANY,

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Defendant.

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EULER HERMES AMERICAN CREDIT
INDEMNITY COMPANY,

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Counterclaim Plaintiff,

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BN 13902513v1

STIPULATION AND [PROPOSED] ORDER RE CONTINUING CMC

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vs.

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NATURE’S OWN PHARMACY, LLC,
RICHARD WALLACE; RICHARD
WALLACE, et al.,

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Counterclaim Defendants.
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Plaintiff and Counter-Claim Defendant Marble Bridge Funding Group (“Marble Bridge”)

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and Defendant and Counter-Claim Plaintiff Euler Hermes American Credit Indemnity Company

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(now known as Euler Hermes North America Insurance Company) (“Euler Hermes”), by and

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through their respective counsel, hereby stipulate and agree, and request the Court to so order, to

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reschedule the Case Management Conference set for May 3, 2013 to June 28, 2013. This is the

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first request to extend the CMC and the parties believe it will have no overall effect on the

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administration of this case.

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Good cause exists to reschedule the CMC. On April 5, 2013, Marble Bridge consented to

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the substitution of Buchalter Nemer as its counsel. Marble Bridge seeks the continuance to

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provide its counsel with a reasonable opportunity to review the files in this action and prepare for

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the CMC.

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Further, counsel for Marble Bridge and Euler Hermes would like additional time to confer

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regarding discovery and a joint case management conference statement. The remaining parties

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are not expected to appear because of pending criminal charges.

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BN 13902513v1

-2STIPULATION AND [PROPOSED] ORDER RE CONTINUING CMC

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Dated: April 29, 2013

BUCHALTER NEMER

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By:

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Dated: April 29, 2013

/s/ Randall L. Manvitz
Randall L. Manvitz
Attorney for Plaintiff and Counter-Claim
Defendant MARBLE BRIDGE FUNDING
GROUP

HALPERIN BATTAGLIA RAICHT, LLP

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By:

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/s/ Neal W. Cohen
Neal W. Cohen
Attorney for Defendant and Counter-Claim
Plaintiff EULER HERMES AMERICAN
CREDIT INDEMNITY COMPANY now
known as EULER HERMES NORTH
AMERICA INSURANCE COMPANY

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BN 13902513v1

-3STIPULATION AND [PROPOSED] ORDER RE CONTINUING CMC

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ORDER
PURSUANT TO THE PARTIES’ STIPULATION, IT IS ORDERED AS FOLLOWS:
The Case Management Conference is rescheduled from May 3, 2013 to June 28, 2013.
The parties shall file an updated joint case management conference statement on or
before June 21, 2013
IT IS SO ORDERED.

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Dated: April ______, 2013

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Honorable Edward J. Davila
Judge of the Northern District Court

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BN 13902513v1

-4STIPULATION AND [PROPOSED] ORDER RE CONTINUING CMC

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CERTIFICATE OF SERVICE

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I, Randall L. Manvitz, hereby certify that on this 29th day of April 2013, a true and correct

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copy of the foregoing document was filed electronically. Notice of this filing will be sent by

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electronic mail to all counsel of record by operation of the Court’s electronic filing system.

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Parties may access this filing through the Court’s system. A paper copy was sent, via U.S. Mail,

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to the following individuals:

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Richard Wallace
712 93rd Avenue North
St. Petersburg, FL 33702
0084362 Marsha Holloway
c/o Marion County Jail
700 NW 30th Avenue
Ocala, FL 34475

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By: /s/ Randall L. Manvitz

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BN 13902513v1

-5STIPULATION AND [PROPOSED] ORDER RE CONTINUING CMC