Federal Deposit Insurance Corporation v. Varrasso et al

Filing 119

STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 10/21/13 ORDERING the parties hereby stipulate to continue the deadline to complete discovery to December 20, 2013, to allow the parties to mediate the case and complete discovery, if so necessary. No other provision of the Pretrial Scheduling Order is to be modified at this time. (Becknal, R)

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SUSAN D. CONDON (State Bar No. 143417)
[e-mail]
VALERIE M. WAGNER (State Bar No. 173146)
[e-mail]
GCA LAW PARTNERS LLP
2570 W. El Camino Real, Suite 510
Mountain View, CA 94043
Telephone: [phone]
Facsimile: [phone]
Attorneys for FEDERAL
DEPOSIT INSURANCE
CORPORATION as Receiver for
INDYMAC BANK, F.S.B.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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SACRAMENTO

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FEDERAL DEPOSIT INSURANCE
CORPORATION as Receiver for
INDYMAC BANK, F.S.B.,
Plaintiff,

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vs.
RICHARD K. VARRASSO dba
Richard Varrasso and Associates and
AppraisalTrust.com, an individual;
PREMIER VALLEY, INC. dba
CENTURY 21 M&M ASSOCIATES, a
California corporation; and KAREN
BHATTI, an individual,

Case No. CIV. 2:11-2628 WBS CKD
STIPULATION AND PROPOSED
ORDER TO MODIFY
SCHEDULING ORDER
REGARDING DISCOVERY
DEADLINE
Honorable Carolyn K. Delaney
Trial: March 25, 2014

Defendants,
And Related Cross-Actions

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STIPULATION
Pursuant to this Court’s Order regarding the scheduling of the above-

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referenced action, (Docket No. 88 dated January 31, 2013), the deadline to

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complete discovery, including expert discovery is October 29, 2013, the final

GCA Law Partners LLP
2570 W. El Camino Real Suite 510
Mountain View, CA 94040
[phone]

Stipulation to Extend Discovery Deadlines
Case No. CIV. 2:11-2628 WBS CKD

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pretrial conference is scheduled for January 21, 2014 and the trial is scheduled

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for March 25, 2014. Pursuant to the Court’s order, the parties have disclosed

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experts and rebuttal experts. While the parties have noticed depositions to be

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completed this month, they believe that the matter is ripe for mediation and

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would prefer to do so before expending additional sums to prepare for trial.
Therefore, the parties1 hereby stipulate and seek leave of Court to continue

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the deadline to complete discovery to December 20, 2013, to allow the parties to

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mediate the case and complete discovery, if so necessary.

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No other provision of the Pretrial Scheduling Order is to be modified at
this time.

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IT IS SO STIPULATED.

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DATED: October 18, 2013

GCA LAW PARTNERS LLP

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By:___/s/ Susan Condon__________
SUSAN CONDON
Attorney for Plaintiff FEDERAL
DEPOSIT INSURANCE
CORPORATION as RECEIVER for
INDYMAC BANK, F.S.B.

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GCA Law Partners LLP
2570 W. El Camino Real Suite 510
Mountain View, CA 94040
[phone]

Cross-Defendant Sophie Reisiyannejad did not respond to the request to so stipulate. Plaintiff’s counsel,
Susan Condon, was contacted by Ms. Reisiyannejad in mid-September and advised that she would be
traveling to Iran on or about October 10, 2013 to care for a family member for a month or two.
Nevertheless, on the morning of October 18, 2013, Ms. Condon phoned Ms. Reisiyannejad and left a
message for Ms. Reisiyannejad, but did not get a response. Counsel for Defendants, Cory Chartrand,
emailed Ms. Reisiyannejad on October 17, 2013 and did not get a response. Therefore, the parties assume
she is currently in Iran.

Stipulation to Extend Discovery Deadlines
Case No. CIV. 2:11-2628 WBS CKD

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DATED: October 18, 2013

TRIEBSCH & FRAMPTON

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By:___/s/ Cory B. Chartrand_____
CORY B. CHARTRAND
Attorneys for Defendants, PREMIER
VALLEY, INC., DBA CENTURY
21 M&M AND ASSOCIATES, and
KAREN BHATTI
(as Authorized on October 18, 2013)

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DATED: October 18, 2013

Richard Varrasso

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By:___/s/ Richard Varrasso_____
Appearing Pro Se

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(as Authorized on October 18, 2013)

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DATED: October 18, 2013

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LAW OFFICES OF STEVEN MIYAKE
By:___/s/ Steven S. Miyake_____
Steven S. Miyake
Attorneys for Cross-Defendant
JOSIE RICH
(as Authorized on October 18, 2013)

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DATED: October 18, 2013

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EMMANUEL KIM
By:___/s/ Emmanuel Kim______
Appearing Pro Se
(as Authorized on October 18, 2013)

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DATED:

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SOPHIE REISIYANNEJAD
By: Please see Footnote 1_
Appearing Pro Se

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GCA Law Partners LLP
2570 W. El Camino Real Suite 510
Mountain View, CA 94040
[phone]

Stipulation to Extend Discovery Deadlines
Case No. CIV. 2:11-2628 WBS CKD

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated: October 21, 2013

_____________________________________
CAROLYN K. DELANEY
UNITED STATES MAGISTRATE JUDGE

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GCA Law Partners LLP
2570 W. El Camino Real Suite 510
Mountain View, CA 94040
[phone]

Stipulation to Extend Discovery Deadlines
Case No. CIV. 2:11-2628 WBS CKD

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