Stipulation And Order For An Extended Briefing Schedule For
Defendants' Demurrers And Motions To Strike In Response To Plaintiff's
Second Amended Complaint Filed By
Ruiz, Carmen Dba El Latino Newspaper, On Behalf Of Herself And
All Others Similary Situated
Carmen Ruiz Dba El Latino Newspaper,
Hartford Accident And Indemnity Company
Hartford Casualty Insurance Company
Hartford Fire Insurance Company
Hartford Insurance Company Of The Midwest
Hartford Underwriters Insurance Company
Superior Access Insurance Services
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L_
CARMEN RUIZ VS. HARTFORD ACCIDENT AND INDEMNITY COMPANY et al
001001826120
Instructions: |
Please place this sheet on top of the document to be scanned.
|Page 2 RECEIVED
07/13/07
DAN MARM
Email: DMarr
FIRST LEGAL 4156261331
ALEFSKY (BAR NO. 95477)
nalefsky@mofo.com San Francisco County Superior Court
WENDY J. RAY (BAR NO. 226269)
Email: WRay@mofo.com JUL 1 7 2007
MORRISON & FOERSTER LLP ,
555 West Fifth Street GORDON, PARK-LI, Clerk
Los Angeles, California 90013-1024 BY: tu
Telephone: 213.892.5200
Deputy Cierk
Facsimile: 213.892.5454
Attorneys for Defendants
Hartford Accident And Indemnity Company, Hartford Casualty
Insurance Company, Hartford Fire Insurance Company, —_ -
Hartford Insurance Company Of The Midwest and Hartford
Underwriters Insurance Company
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Carmen Ruiz,
behalf of herself and all others similarly situated,
dba El Latino Newspaper, on CaseNo. CGC.06 451270
Plaintiff, STIPULATION AND [PROPOSED
ORDER FOR AN EXTENDED
v. BRIEFING SCHEDULE FOR
DEFENDANTS’ DEMURRERS AND
Hartford Accident And Indemnity Company, MOTIONS TO STRIKE IN
Hartford Casualty Insurance Company, Hartford RESPONSE TO PLAINTIFF’S
Fire Insurance Company, Hartford Insurance
Company Of The Midwest, Hartford
Underwriters Insurance Company, Superior
Access Insurance Services and Does'1 through
100 inclusive,
SECOND AMENDED COMPLAINT
Complaint Filed:
Trial Date:
April 14, 2006
Defendants. . None Set
STIPULATION
1a-928399
AND [PROPOSED] ORDER RE EXTENDED BRIEFING SCHEDULE FOR DEMURRERS & MOTIONS
TO STRIKE IN RESPONSE TO PLAINTIFF’S SECOND AMENDED COMPLAINTPage 3 bk WwW WN
in
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Oo oOo “I SN
omar
FIRST LEGAL 4156261331
Plaintiff Carmen Ruiz dba El Latino Newspaper (“Plaintiff”), defendant Superior Access
Insurance Services and defendants Hartford Accident And Indemnity Company, Hartford Casualty
Midwest and
through their
1.
arbitration de
2.
. Insurance Company, Hartford Fire Insurance Company, Hartford Insurance Company of The
Hartford Underwriters Insurance Company (collectively, “The Hartford Defendants”),
respective undersigned counsel, stipulate as follows.
RECITALS
| Counsel for The Hartford Defendants is presently working to meet substantial pre-
adlines.
The parties to this action have conferred and reached an agreement that an extended
briefing schedule for the anticipated demurrers and motions to strike to be filed in response to
Plaintiff's Ses
NOW
schedule:
1.
Hartford and
2.
3.
4.
tond Amended Complaint is reasonable under the circumstances.
STIPULATION
THEREFORE, the parties to this action hereby stipulate to the following briefing
Demurrers and Motions to Strike (if any) (the “Motions”) are to be filed by The
Superior on August 13, 2007. |
Plaintiff s oppositions to the Motions are to be filed on September 21, 2007.
Defendants reply briefs are to be filed on September 28, 2007.
The parties agree that they will fax or e-mail copies of their respective briefs to
counsel for all parties on the day each brief is filed in addition to the required overnight delivery of
hard copies of their respective papers.
Mt
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STIPULATION AND [PROPOSED] ORDER RE EXTENDED BRIEFING SCHEDULE FOR DEMURRERS & MOTIONS
la-928399
TO STRIKE IN RESPONSE TO PLAINTIFF’S SECOND AMENDED COMPLAINTPage 4 86/04/2887 88: 43/1307 415 FIRST LEGAL 4156261331
. PAGE 4
1 5. The parties will seek an October 5, 2007 hearing date for the Motions.
2 TT IS SO STIPULATED.
31 pated: uly _// _, 2007 GERARDO C. SANDOVAL
A ATTORNEY AT LAW
5 By:
ardo C. Sa i
6 Attorneys for Plaintiff
7 Carmen Ruiz dba E} Latino Newspaper
8 Dated: July , 2007 DAN MARMALEFSKY
WENDY J. RAY
9 MORRISON & FOERSTER LLP
14 Wendy J. Ray
Attomeys for Defendants
12 Hartford Accident and Indempity Company,
Hartford Casualty Insurance Company,
13 Hartford Fire Insurance Company, Hartford
insurance Company of The Midwest and
14 Hartford Underwriters Insurance Company
15 Dated: July , 2007 DAVID F. HAUGE
DONALD E. CHOMIAK
16 SONNENSCHEIN, NATH & ROSENTHAL LLP
17 By: cee page
18 Donald E, Chomiak
Attomeys for Defendant
19 Superior Access Insurance Services
20
ORDER
21 Pursuant to the Stipulation set forth above, and good cause having been found, the above
22 | briefing schedule is adopted.
2 IS SO ORDERED. | 2
24
Dated: 2007 \ Ue |
25 Hon. Robert L. Dondero
Superior Court Judge
26
27 |
28
s TION AND [PROPOSED ORDER RE EXTENDED BRIEFING SCHEDULE FOR DEMURRERS & MOTIONS
wy we ProennawEed TH Th avareroirs crema shcONNON oman ATTPage 5 07-11-07
Oo Om VY DH NH SF Ww NY &
ttt me meet ee
on sus BO AH RP Ww NY KY S&S
0713/07 FIRST LEGAL 4156261331
03:53pm = From
T-058 =P.O1/01 = F-725
The parties will seek an October 5, 2007 heanng date for the Motions.
5.
IT IS SOSTIPULATED.
Dated: July , 2007 GERARDO C. SANDOVAL
ATTORNEY AT LAW.
By:
Gerardo C. Sandoval
Attomeys for Plainuff
Carmen Ruiz dba E] Latino Newspaper
Dated: July iZ , 2007 DAN MARMALFFSKY
WENDY J. RAY
MORRISON & FOERSTER tip
By:
Attorneys for Defendants
Hartford Accident and Indemnity Company,
Hartford Casualty Insurance Company,
Hartford Fire Insurance Company, Hartford
Insurance Company of The Midwest and
Hartford Underwniters Insurance Company
Dated: July _/|_., 2007 DAVID F. HAUGE
DONALD E. CHOMIAK
so CHEIN, NATH & ROSENTHAL itp
By:
Attomeys for Defendant
Superior Access Insurance Services
o™ ORDER
Pursuant to [ inulation set forth ahove, and good cause having been fo
briefing schedule is adopted.
iT
{S SO ORDERED.
Dated: __| , 2007
Hon. Robert L. Dondero hh,
Superior Court Judge
oo
| yt.
STIPULATION AND [PROPOSED] QROER RE EXTENDED BRIEFING SCHEDULE FOR DEMURRERS & MOTIONS
la-928399
TO STRIKE IN RESPONSE TQ PLAINTIFF’S SECOND AMENDED COMPLAINT
PDF Page 1
PlainSite Cover Page
PDF Page 2
WN
San Francisco Superior Courts
Information Technology Group
Document Scanning Lead Sheet
Jul-17-2007 11:31 am
Case Number: CGC-06-451270
Filing Date: Jul-17-2007 11:29
Juke Box: 001 Image: 01826120
STIPULATION
L_
CARMEN RUIZ VS. HARTFORD ACCIDENT AND INDEMNITY COMPANY et al
001001826120
Instructions: |
Please place this sheet on top of the document to be scanned.
|
PDF Page 3
RECEIVED
07/13/07
DAN MARM
Email: DMarr
FIRST LEGAL 4156261331
ALEFSKY (BAR NO. 95477)
nalefsky@mofo.com San Francisco County Superior Court
WENDY J. RAY (BAR NO. 226269)
Email: WRay@mofo.com JUL 1 7 2007
MORRISON & FOERSTER LLP ,
555 West Fifth Street GORDON, PARK-LI, Clerk
Los Angeles, California 90013-1024 BY: tu
Telephone: 213.892.5200
Deputy Cierk
Facsimile: 213.892.5454
Attorneys for Defendants
Hartford Accident And Indemnity Company, Hartford Casualty
Insurance Company, Hartford Fire Insurance Company, —_ -
Hartford Insurance Company Of The Midwest and Hartford
Underwriters Insurance Company
SUPERIOR COURT OF THE STATE OF CALIFORNIA
COUNTY OF SAN FRANCISCO
Carmen Ruiz,
behalf of herself and all others similarly situated,
dba El Latino Newspaper, on CaseNo. CGC.06 451270
Plaintiff, STIPULATION AND [PROPOSED
ORDER FOR AN EXTENDED
v. BRIEFING SCHEDULE FOR
DEFENDANTS’ DEMURRERS AND
Hartford Accident And Indemnity Company, MOTIONS TO STRIKE IN
Hartford Casualty Insurance Company, Hartford RESPONSE TO PLAINTIFF’S
Fire Insurance Company, Hartford Insurance
Company Of The Midwest, Hartford
Underwriters Insurance Company, Superior
Access Insurance Services and Does'1 through
100 inclusive,
SECOND AMENDED COMPLAINT
Complaint Filed:
Trial Date:
April 14, 2006
Defendants. . None Set
STIPULATION
1a-928399
AND [PROPOSED] ORDER RE EXTENDED BRIEFING SCHEDULE FOR DEMURRERS & MOTIONS
TO STRIKE IN RESPONSE TO PLAINTIFF’S SECOND AMENDED COMPLAINT
PDF Page 4
bk WwW WN
in
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11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Oo oOo “I SN
omar
FIRST LEGAL 4156261331
Plaintiff Carmen Ruiz dba El Latino Newspaper (“Plaintiff”), defendant Superior Access
Insurance Services and defendants Hartford Accident And Indemnity Company, Hartford Casualty
Midwest and
through their
1.
arbitration de
2.
. Insurance Company, Hartford Fire Insurance Company, Hartford Insurance Company of The
Hartford Underwriters Insurance Company (collectively, “The Hartford Defendants”),
respective undersigned counsel, stipulate as follows.
RECITALS
| Counsel for The Hartford Defendants is presently working to meet substantial pre-
adlines.
The parties to this action have conferred and reached an agreement that an extended
briefing schedule for the anticipated demurrers and motions to strike to be filed in response to
Plaintiff's Ses
NOW
schedule:
1.
Hartford and
2.
3.
4.
tond Amended Complaint is reasonable under the circumstances.
STIPULATION
THEREFORE, the parties to this action hereby stipulate to the following briefing
Demurrers and Motions to Strike (if any) (the “Motions”) are to be filed by The
Superior on August 13, 2007. |
Plaintiff s oppositions to the Motions are to be filed on September 21, 2007.
Defendants reply briefs are to be filed on September 28, 2007.
The parties agree that they will fax or e-mail copies of their respective briefs to
counsel for all parties on the day each brief is filed in addition to the required overnight delivery of
hard copies of their respective papers.
Mt
Mt
Mf
Mt
Mt
Mf
Mt
1
STIPULATION AND [PROPOSED] ORDER RE EXTENDED BRIEFING SCHEDULE FOR DEMURRERS & MOTIONS
la-928399
TO STRIKE IN RESPONSE TO PLAINTIFF’S SECOND AMENDED COMPLAINT
PDF Page 5
86/04/2887 88: 43/1307 415 FIRST LEGAL 4156261331
. PAGE 4
1 5. The parties will seek an October 5, 2007 hearing date for the Motions.
2 TT IS SO STIPULATED.
31 pated: uly _// _, 2007 GERARDO C. SANDOVAL
A ATTORNEY AT LAW
5 By:
ardo C. Sa i
6 Attorneys for Plaintiff
7 Carmen Ruiz dba E} Latino Newspaper
8 Dated: July , 2007 DAN MARMALEFSKY
WENDY J. RAY
9 MORRISON & FOERSTER LLP
14 Wendy J. Ray
Attomeys for Defendants
12 Hartford Accident and Indempity Company,
Hartford Casualty Insurance Company,
13 Hartford Fire Insurance Company, Hartford
insurance Company of The Midwest and
14 Hartford Underwriters Insurance Company
15 Dated: July , 2007 DAVID F. HAUGE
DONALD E. CHOMIAK
16 SONNENSCHEIN, NATH & ROSENTHAL LLP
17 By: cee page
18 Donald E, Chomiak
Attomeys for Defendant
19 Superior Access Insurance Services
20
ORDER
21 Pursuant to the Stipulation set forth above, and good cause having been found, the above
22 | briefing schedule is adopted.
2 IS SO ORDERED. | 2
24
Dated: 2007 \ Ue |
25 Hon. Robert L. Dondero
Superior Court Judge
26
27 |
28
s TION AND [PROPOSED ORDER RE EXTENDED BRIEFING SCHEDULE FOR DEMURRERS & MOTIONS
wy we ProennawEed TH Th avareroirs crema shcONNON oman ATT
PDF Page 6
07-11-07
Oo Om VY DH NH SF Ww NY &
ttt me meet ee
on sus BO AH RP Ww NY KY S&S
0713/07 FIRST LEGAL 4156261331
03:53pm = From
T-058 =P.O1/01 = F-725
The parties will seek an October 5, 2007 heanng date for the Motions.
5.
IT IS SOSTIPULATED.
Dated: July , 2007 GERARDO C. SANDOVAL
ATTORNEY AT LAW.
By:
Gerardo C. Sandoval
Attomeys for Plainuff
Carmen Ruiz dba E] Latino Newspaper
Dated: July iZ , 2007 DAN MARMALFFSKY
WENDY J. RAY
MORRISON & FOERSTER tip
By:
Attorneys for Defendants
Hartford Accident and Indemnity Company,
Hartford Casualty Insurance Company,
Hartford Fire Insurance Company, Hartford
Insurance Company of The Midwest and
Hartford Underwniters Insurance Company
Dated: July _/|_., 2007 DAVID F. HAUGE
DONALD E. CHOMIAK
so CHEIN, NATH & ROSENTHAL itp
By:
Attomeys for Defendant
Superior Access Insurance Services
o™ ORDER
Pursuant to [ inulation set forth ahove, and good cause having been fo
briefing schedule is adopted.
iT
{S SO ORDERED.
Dated: __| , 2007
Hon. Robert L. Dondero hh,
Superior Court Judge
oo
| yt.
STIPULATION AND [PROPOSED] QROER RE EXTENDED BRIEFING SCHEDULE FOR DEMURRERS & MOTIONS
la-928399
TO STRIKE IN RESPONSE TQ PLAINTIFF’S SECOND AMENDED COMPLAINT
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