Federal Deposit Insurance Corporation v. Varrasso et al
Filing
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STIPULATION and ORDER signed by Magistrate Judge Carolyn K. Delaney on 12/9/2013 ORDERING that the Court GRANTS the parties' request to continue the deadline to complete discovery to 1/20/2014. (Zignago, K.)
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SUSAN D. CONDON (State Bar No. 143417)
scondon@gcalaw.com
VALERIE M. WAGNER (State Bar No. 173146)
vwagner@gcalaw.com
GCA LAW PARTNERS LLP
2570 W. El Camino Real, Suite 510
Mountain View, CA 94043
Telephone: (650) 428-3900
Facsimile: (650) 428-3901
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
Honorable William Shubb
Trial: March 25, 2014
Defendants,
And Related Cross-Actions
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STIPULATION
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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 final pretrial
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conference is scheduled for January 21, 2014 with a final pretrial statement due
GCA Law Partners LLP
2570 W. El Camino Real Suite 510
Mountain View, CA 94040
(650)428-3900
Stipulation to Extend Deadlines
Case No. CIV. 2:11-2628 WBS CKD
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on January 8, 2014, and the trial is scheduled for March 25, 2014. On October
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22, 2013 (Docket No. 119), this Court agreed to extend the discovery deadline to
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December 20, 2013 so that the parties could engage in settlement discussions.
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On November 26, 2013, Plaintiff FDIC as Receiver for IndyMac Bank, F.S.A.
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(“FDIC-R”) and Defendants Karen Bhatti, Premier Valley dba Century 21
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M&M, Richard Varrasso, and Cross-Defendant Emmanuel Kim attended a
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mediation conducted by Brad Benning. While the parties have not yet settled the
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case, sufficient progress was made to schedule a second mediation on December
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23, 2013.
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In light of the foregoing, the Parties desire to again continue the discovery
deadline an additional 30 days to January 20, 2014 in order to allow the parties
to mediate on December 23, 2013 and complete discovery afterwards, if
necessary. Given that the final pretrial statement is due on January 7, 2014 and
the final pretrial conference is scheduled for February 21, 2014, the parties also
desire a continuance of the final pretrial conference an additional few weeks, to a
date available on the Court’s calendar. Should the Court find it necessary to
continue the trial a brief time, the parties are likewise amenable.
Therefore, the parties1 hereby stipulate and respectfully seek leave of
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Court to continue the deadline to complete discovery to January 20, 2014, to
allow the parties to mediate the case and complete discovery as necessary, as
well as continue the final pretrial conference.
IT IS SO STIPULATED.
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DATED: December 4, 2013
GCA LAW PARTNERS LLP
By:___/s/ Susan Condon__________
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GCA Law Partners LLP
2570 W. El Camino Real Suite 510
Mountain View, CA 94040
(650)428-3900
We are advised by the husband of Cross-Defendant Sophie Reisiyannejad that she remains out of the
country and therefore is not available to stipulate. Further, Defendant Josie Rich has filed a notice of
bankruptcy and therefore she has not been party to the settlement discussions or this stipulation.
Stipulation to Extend Deadlines
Case No. CIV. 2:11-2628 WBS CKD
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SUSAN CONDON
Attorney for Plaintiff FEDERAL
DEPOSIT INSURANCE
CORPORATION as RECEIVER for
INDYMAC BANK, F.S.B.
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DATED: December 4, 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 December 3, 2013)
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DATED: December 4, 2013
Richard Varrasso
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By:___/s/ Richard Varrasso_____
Appearing Pro Se
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(as Authorized on December 3, 2013)
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DATED: December 4, 2013
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By:___/s/ Emmanuel Kim______
Appearing Pro Se
(as Authorized on December 3, 2013)
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DATED:
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By: Please see Footnote 1_
Appearing Pro Se
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SOPHIE REISIYANNEJAD
PURSUANT TO STIPULATION, IT IS SO ORDERED.
The Court hereby grants the parties’ request to continue the deadline
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to complete discovery to January 20, 2014, to allow the parties to mediate
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the case and complete discovery as necessary.
GCA Law Partners LLP
2570 W. El Camino Real Suite 510
Mountain View, CA 94040
(650)428-3900
Stipulation to Extend Deadlines
Case No. CIV. 2:11-2628 WBS CKD
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The parties are advised, however, that the pretrial conference date
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cannot be continued in the absence of a continuation of the trial date. A
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separate request must be made to the District Judge assigned to this action
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should the parties desire a continuance of the final pretrial conference.
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Dated: December 9, 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
(650)428-3900
Stipulation to Extend Deadlines
Case No. CIV. 2:11-2628 WBS CKD
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