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United States v. Gonzales & Gonzales Bonds & Ins. Agency, Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION
Nov 18, 2011
Case No. C 09-04029 EMC (N.D. Cal. Nov. 18, 2011)

Opinion

Case No. C 09-04029 EMC

11-18-2011

UNITED STATES OF AMERICA, Plaintiff, v. GONZALES & GONZALES BONDS AND INSURANCE AGENCY, INC. and AMERICAN SURETY COMPANY, INC., Defendants. GONZALES & GONZALES BONDS AND INSURANCE AGENCY, INC. and AMERICAN SURETY COMPANY, INC. Counterclaimants, v. UNITED STATES DEPARTMENT OF HOMELAND SECURITY, JANET NAPOLITANO, in her capacity as SECRETARY OF UNITED STATES DEPARTMENT OF HOMELAND SECURITY Counterdefendants.

ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP TONY WEST Assistant Attorney General MELINDA HAAG United States Attorney John J. Siemietkowski_ J. CHRISTOPHER KOHN RUTH A. HARVEY E. KATHLEEN SHAHAN (D.C. Bar No. 267872) JOHN J. SIEMIETKOWSKI (PA Bar. No. 50346) FRANCES M. MCLAUGHLIN GARY A. NYE DAVID R. GINSBURG Attorneys for Defendants/Counterclaimants GONZALES & GONZALES BONDS AND INSURANCE AGENCY, INC. and AMERICAN SURETY COMPANY, INC. (FL Bar No. 0256640) Trial Attorneys Civil Division, Commercial Litigation Branch Attorneys for the United States of America


UNITED STATES DEPARTMENT OF JUSTICE

Ruth A. Harvey, Assistant Director

Frances M. McLaughlin

E. Kathleen Shahan

John J. Siemietkowski

Trial Attorneys

Attorneys for Plaintiff

STIPULATION TO ENLARGE TIME FOR

FILING GOVERNMENT RESPONSE TO

G&G/ASC FIRST AMENDED

COUNTERCLAIM ;ORDER


Pursuant to Civil L.R. 6-1(a), Plaintiff United States of America, Counterdefendants United States Department of Homeland Security and Janet Napolitano, in her capacity as Secretary of United States Department of Homeland Security (collectively "United States"), on the one hand, and Defendants/Counterclaimants Gonzales & Gonzales Bonds and Insurance Agency, Inc. and American Surety Company, Inc. ("G&G/ASC"), on the other hand, by and through their respective counsel of record, bring this administrative motion by stipulation, and stipulate and agree as follows:

1. On November 14, 2011, G&G/ASC filed its first amended counterclaim, dkt. 94, which added twenty-eight bond breach determinations to the six in its original counterclaim, dkt. 9.

2. Per FED. R. CIV. P. 15(a)(3), the United States has until November 28, 2011, to file a response to G&G/ASC's first amended counterclaim.

3. Given the twenty-eight new bond breach determinations in G&G/ASC's first amended counterclaim, and considering the approaching holiday season, the United States will not be in a position to respond to G&G/ASC's first amended counterclaim by November 28.

4. Therefore, the parties stipulate that the United States' time to respond to G&G/ASC's first amended counterclaim is enlarged until December 30, 2011.

IT IS SO STIPULATED.

ROXBOROUGH, POMERANCE, NYE & ADREANI, LLP

TONY WEST

Assistant Attorney General

MELINDA HAAG

United States Attorney

John J. Siemietkowski_

J. CHRISTOPHER KOHN

RUTH A. HARVEY

E. KATHLEEN SHAHAN

(D.C. Bar No. 267872)

JOHN J. SIEMIETKOWSKI

(PA Bar. No. 50346)

FRANCES M. MCLAUGHLIN

GARY A. NYE

DAVID R. GINSBURG

Attorneys for Defendants/Counterclaimants

GONZALES & GONZALES BONDS AND

INSURANCE AGENCY, INC. and AMERICAN

SURETY COMPANY, INC.

(FL Bar No. 0256640)

Trial Attorneys

Civil Division, Commercial Litigation

Branch

Attorneys for the United States of

America

IT IS SO ORDERED:

Edward M. Chen

U.S. District Judge


Summaries of

United States v. Gonzales & Gonzales Bonds & Ins. Agency, Inc.

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION
Nov 18, 2011
Case No. C 09-04029 EMC (N.D. Cal. Nov. 18, 2011)
Case details for

United States v. Gonzales & Gonzales Bonds & Ins. Agency, Inc.

Case Details

Full title:UNITED STATES OF AMERICA, Plaintiff, v. GONZALES & GONZALES BONDS AND…

Court:UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION

Date published: Nov 18, 2011

Citations

Case No. C 09-04029 EMC (N.D. Cal. Nov. 18, 2011)