Cortes v. National Credit Adjusters, L.L.C.

Filing 40

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 7/18/19 EXTENDING deadline to file dispositional papers pursuant to Local Rule 160 to August 9, 2019. (Kaminski, H)

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BURSOR & FISHER, P.A.
L. Timothy Fisher (State Bar No. 191626)
Yeremey O. Krivoshey (State Bar No.295032)
1990 North California Blvd., Suite 940
Walnut Creek, CA 94596
Telephone: [phone]
Email: [e-mail]
[e-mail]
BURSOR & FISHER, P.A.
Scott A. Bursor (State Bar No. 276006)
2665 S. Bayshore Dr., Suite 220
Miami, FL 33133-5402
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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MIKE CORTES, on Behalf of Himself and all
Others Similarly Situated,

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Plaintiff,
v.

Case No. 2:16-cv-00823-MCE-EFB
STIPULATION TO CONTINUE
DEADLINE TO FILE DISPOSITIONAL
PAPERS PURSUANT TO LOCAL
RULE 160 AND ORDER

NATIONAL CREDIT ADJUSTERS, L.L.C.,
Defendant.

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STIPULATION TO CONTINUE DEADLINE TO FILE DISPOSITIONAL PAPERS
CASE NO. 2:16-CV-00823-MCE-EFB

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Pursuant to Civil Local Rule 143, Plaintiff Mike Cortes (“Plaintiff”) and Defendant National

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Credit Adjusters, L.L.C. (“Defendant”) (collectively, the “Parties”), by and through their respective

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counsel, stipulate as follows:

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WHEREAS, on January 18, 2019, the Parties participated in a mediation with Martin Quinn,
Esq., at JAMS in San Francisco, California;
WHEREAS, on February 5, 2019, the Parties executed a binding Term Sheet setting out an
agreement to settle all claims in this action on a class basis;
WHEREAS, on February 6, 2019, upon stipulation of the Parties and notice of the settlement,
the Court vacated all remaining pretrial deadlines and ordered the Parties to file dispositional papers
pursuant to Local Rule 160 by February 28, 2019 (Dkt. No. 35);
WHEREAS, on June 28, 2019, upon stipulation of the Parties, the Court extended the Parties’
deadline to file dispositional papers pursuant to Local Rule 160 to June 28, 2019 (Dkt. 37);
WHEREAS, the Parties have made significant progress but need more time to finalize the full

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class settlement agreement (along with all of the relevant exhibits thereto, i.e., long form and short-

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form notice documents, proposed final approval and judgment orders, etc.);

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WHEREAS, once the full class settlement agreement is executed, Plaintiff intends to file a

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motion for preliminary approval of the settlement and provide the Court with a copy of the executed

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class settlement agreement at that time;

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WHEREAS, due to the extensive time needed to draft (and negotiate) the full class action

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settlement agreement and the motion for preliminary approval, the Parties anticipate that they will be

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able to execute the class action settlement agreement and that Plaintiff will be able to file a motion

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for preliminary approval by August 9, 2019;

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NOW THEREFORE, IT IS STUPULATED AND AGREED by the Parties, by and through

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their counsel, that the Parties’ deadline to file dispositional papers pursuant to Local Rule 160 shall

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be extended to August 9, 2019.

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STIPULATION TO CONTINUE DEADLINE TO FILE DISPOSITIONAL PAPERS
CASE NO. 2:16-CV-00823-MCE-EFB

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Dated: June 28, 2019

BURSOR & FISHER, P.A.

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By:

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BURSOR & FISHER, P.A.
Scott A. Bursor (State Bar No. 276006)
2665 S. Bayshore Dr., Suite 220
Miami, FL 33133-5402
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]

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Attorneys for Plaintiff

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/s/ Yeremey Krivoshey
Yeremey Krivoshey

L. Timothy Fisher (State Bar No. 191626)
Yeremey Krivoshey (State Bar No. 295032)
1990 North California Boulevard, Suite 940
Walnut Creek, CA 94596
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
[e-mail]

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Respectfully submitted,

Dated: June 28, 2019

SESSIONS, FISHMAN, NATHAN & ISRAEL, L.L.P.
By:

/s/ James K. Schultz
James K. Schultz

James K. Schultz (State Bar No. 309945)
Debbie P. Kirkpatrick (State Bar No. 207112)
1545 Hotel Circle South, Suite 150
San Diego, CA 92108
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
[e-mail]
Attorneys for Defendant National Credit Adjusters, LLC

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STIPULATION TO CONTINUE DEADLINE TO FILE DISPOSITIONAL PAPERS
CASE NO. 2:16-CV-00823-MCE-EFB

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ORDER

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IT IS HEREBY ORDERED the Parties’ deadline to file dispositional papers pursuant to
Local Rule 160 shall be extended to August 9, 2019.
IT IS SO ORDERED.
Dated: July 18, 2019

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STIPULATION TO CONTINUE DEADLINE TO FILE DISPOSITIONAL PAPERS
CASE NO. 2:16-CV-00823-MCE-EFB

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