Jacques vs. Bank of America Corporation, et al.

Filing 17

STIPULATION and ORDER GRANTING the parties' request for an extension of time to 10/1/2012 for defendants to file a responsive pleading to the amended complaint. The Court further GRANTS the continuance of the Initial Scheduling Conference currently set for 7/31/2012 and CONTINUES it to 10/29/2012 at 09:00 AM in Courtroom 9 (DLB) before Magistrate Judge Dennis L. Beck; order signed by Magistrate Judge Dennis L. Beck on 7/20/2012. (Rooney, M)

1 DOUGLAS TUCKER 172550
HENRY Y. CHIU 222927
2 MOSS, TUCKER, CHIU, HEBESHA & WARD PC
A Professional Corporation
3 5260 North Palm, Suite 205
Fresno, California 93704
4 Telephone: [phone]
Facsimile: [phone]
5
Attorneys for Plaintiff,
6 TROY JACQUES
7
8

UNITED STATES DISTRICT COURT

9

EASTERN DISTRICT OF CALIFORNIA – FRESNO DIVISION

10

* * *

11 TROY JACQUES,
12
13
14
15
16
17
18

)
)
Plaintiff,
)
)
vs.
)
)
BANK OF AMERICA CORPORATION, a )
Delaware corporation, aka BANK OF
)
AMERICA N.A.; FIRST ADVANTAGE )
BACKGROUND SERVICES CORP., a
)
Florida corporation; EARLY WARNING )
SERVICES, LLC, a limited liability
)
company, and DOES 1 through 50,
)
)
Defendants.
)
)

Case No.: 1:12-cv-00821-LJO-DLB

JOINT STIPULATION AND ORDER TO
CONTINUE DEFENDANTS’ DEADLINE
TO FILE RESPONSIVE PLEADING
AND TO CONTINUE MANDATORY
SCHEDULING CONFERENCE

19
20

Plaintiff TROY JACQUES and defendants BANK OF AMERICA CORPORATION, aka

21 BANK OF AMERICA N.A., FIRST ADVANTAGE BACKGROUND SERVICES CORP., and
22 EARLY WARNING SERVICES, LLC (collectively “the Parties”) are currently in the process of
23 exploring an informal resolution of the present action. In light of the upcoming litigation
24 deadlines, the Parties respectfully request the following:
25

1.

that Defendants’ time to respond to the Amended Complaint be extended by sixty

26 (60) days. Defendants were served with the Amended Complaint on July 12, 2012, thereby
27 making their response due on or before August 2, 2012. The Parties jointly agree to extend the
28 deadline for Defendants to file their responses by sixty (60) days to October 1, 2012.
MOSS, TUCKER, CHIU,
HEBESHA & WARD PC
5260 N. PALM AVE., #205
FRESNO, CA 93704

1
JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEFENDANTS’ DEADLINE
TO FILE RESPONSIVE PLEADING AND TO CONTINUE MANDATORY SCHEDULING CONFERENCE

1

2.

that the Mandatory Scheduling Conference currently scheduled for July 31, 2012

2 (and its related deadlines), be continued at least sixty (60) days.
3

Dated: July 19, 2012.

MOSS, TUCKER, CHIU, HEBESHA & WARD PC
By:

4
5

/s/ Henry Y. Chiu
HENRY Y. CHIU
Attorneys for Plaintiff
TROY JACQUES

6
Dated: July 19, 2012.

EDWARDS WILDMAN PALMER LLP

7
By:
8
9

/s/ Patricia S. Riordan
PATRICIA S. RIORDAN
Attorneys for Defendant
BANK OF AMERICA, CORPORATION
aka BANK OF AMERICA, N.A

10
Dated: July 19, 2012.

COLEMAN & HOROWITT, LLP

11
By:
12
13

/s/ Keith M. White
KEITH M. WHITE
Attorneys for Defendant
FIRST ADVANTAGE BACKGROUND
SERVICES CORP

14
Dated: July 19, 2012.

GREENBERG TRAURIG, LLP

15
By:
16
17

/s/ Roger L. Scott
ROGER L. SCOTT
Attorneys for Defendant
EARLY WARNING SERVICES, LLC

18

ORDER

19

Having considered the parties’ Stipulation, this Court hereby ORDERS as follows:

20

1.

The last day for the Defendants’ to respond to the Amended Complaint is hereby

21 extended to October 1, 2012.
22

2.

The Mandatory Scheduling Conference is continued to October 29, 2012 at 9:00

23 am. A Joint Statement is due one week before the conference.
24
25 IT IS SO ORDERED.
26

Dated:

27

July 20, 2012

/s/ Dennis

L. Beck

UNITED STATES MAGISTRATE JUDGE
DEAC_Signature-END:

28

3b142a

MOSS, TUCKER, CHIU,
HEBESHA & WARD PC
5260 N. PALM AVE., #205
FRESNO, CA 93704

2
JOINT STIPULATION AND [PROPOSED] ORDER TO CONTINUE DEFENDANTS’ DEADLINE
TO FILE RESPONSIVE PLEADING AND TO CONTINUE MANDATORY SCHEDULING CONFERENCE