Cortes v. National Credit Adjusters, L.L.C.
Filing
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STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 8/20/2019 EXTENDING deadline to file dispositional papers to 8/23/2019. (Zignago, K.)
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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: (925) 300-4455
Email: ltfisher@bursor.com
ykrivoshey@bursor.com
BURSOR & FISHER, P.A.
Scott A. Bursor (State Bar No. 276006)
2665 S. Bayshore Dr., Suite 220
Miami, FL 33133-5402
Telephone: (305) 330-5512
Facsimile: (305) 676-9006
E-Mail: scott@bursor.com
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 March 5, 2019, upon stipulation of the Parties, the Court extended the
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Parties’ deadline to file dispositional papers pursuant to Local Rule 160 to June 28, 2019 (Dkt. 37);
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WHEREAS, on July 19, 2019, upon stipulation of the Parties, the Court again extended the
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Parties’ deadline to file dispositional papers pursuant to Local Rule 160 to August 9, 2019 (Dkt. 40);
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 orders, etc.);
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WHEREAS, the Parties also require two more weeks to gather and verify contact information
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for as many class members as possible such that the proposed notice plan can provide notice to as
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many class members as reasonably possible;
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WHEREAS, the Parties require a full accounting of class members’ contact information to
provide the Court with sufficient information to evaluate the adequacy of the proposed notice plan;
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 additional time needed to finalize the full class action settlement
agreement and the motion for preliminary approval, the Parties anticipate that they will be able to
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STIPULATION TO CONTINUE DEADLINE TO FILE DISPOSITIONAL PAPERS
CASE NO. 2:16-CV-00823-MCE-EFB
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execute the class action settlement agreement and that Plaintiff will be able to file a motion for
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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 23, 2019.
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Dated: August 9, 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: (305) 330-5512
Facsimile: (305) 676-9006
E-Mail: scott@bursor.com
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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: (925) 300-4455
Facsimile: (925) 407-2700
E-Mail: ltfisher@bursor.com
ykrivoshey@bursor.com
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Respectfully submitted,
Dated: August 9, 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: (619) 758-1891
Facsimile: (619) 296-2013
E-Mail: jschultz@sessions.legal
dkirkpatrick@sessions.legal
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
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Local Rule 160 shall be extended to August 23, 2019.
IT IS SO ORDERED.
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Dated: August 20, 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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