Federal Deposit Insurance Corporation v. Varrasso et al

Filing 66

STIPULATION and ORDER 65 signed by Judge William B. Shubb on 9/26/2012 extending the disclosure of experts to 12/31/2012, and extending the discovery deadline to 1/31/2013. No other provision of the Pretrial Scheduling Order is to be modified. (Kirksey Smith, K)

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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
1891 Landings Dr.
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
Honorable William B. Shubb
Trial: April 16, 2013

Defendants.

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STIPULATION
In light of Defendants’ Motion for Leave to File a Third Party Complaint

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and to Amend the Scheduling Order (Document 61) and Plaintiff’s Notice of

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Non-Opposition to the same (Document 62), the parties, Plaintiff Federal

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Deposit Insurance Corporation as Receiver for IndyMac Bank, F.S.B. and

GCA Law Partners LLP
1891 Landings Drive
Mountain View, CA 94043
[phone]

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

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Defendants Richard Varrasso, Premier Valley Inc. dba Century 21 M&M

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Associates, and Karen Bhatti by and through their counsel of record or

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personally hereby stipulate and agree to modify the Pretrial Scheduling Order in

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this matter to extend the expert disclosure and discovery cutoff dates. Given that

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the information to be reviewed by the experts, as well as the scope of their

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opinions will increase if Defendants’ motion is granted, the Parties agree to

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extend the deadline for the disclosure of expert witnesses until after the motion is

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determined.

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The Court agreed to continue the disclosure of experts and rebuttal experts

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to September 28, 2012 and October 26, 2012 (Document 60). In light of the

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Defendants’ motions, the parties respectfully request that they be permitted to

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disclose experts on November 30, 2012 and December 31, 2012, respectively.
They further stipulate to extend the discovery deadline from November 30, 2012
to January 31, 2013.
No other provision of the Pretrial Scheduling Order is to be modified.

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IT IS SO STIPULATED.
DATED: September 24, 2012

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
1891 Landings Drive
Mountain View, CA 94043
[phone]

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

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DATED: September 24, 2012

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 September 24,
2012)

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DATED: September 26, 2012

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Richard Varrasso

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By:___/s/ Richard Varrasso_____
Appearing Pro Se

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(as Authorized on September 26,

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2012)

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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DATED: September 26, 2012

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GCA Law Partners LLP
1891 Landings Drive
Mountain View, CA 94043
[phone]

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

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