Johnson v. Navient Solutions, Inc.

Filing 37

STIPULATION and ORDER signed by District Judge John A. Mendez on 9/28/17 ORDERING the deadline for Defendant to file its Reply in Support of its Motion for Summary Judgment to 10/31/17; the hearing on Defendant's Motion for Summary Judgment is set for 11/7/17 at 1:30 p.m.; the deadline to file the parties' joint pretrial statement for 1/19/18; Pretrial Conference is set for 1/26/18 at 10:00 a.m.; and Trial is set for 3/12/18 at 09:00 a.m. in Courtroom 6 (JAM) before District Judge John A. Mendez. (Becknal, R)

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Dennis N. Lueck, Jr. (SBN CA 292414)
[e-mail]
HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
Telephone: [phone]
Facsimile:
213-614-7399
Tyler A. Carle (SBN CA 298033)
[e-mail]
HINSHAW & CULBERTSON LLP
One California Street, 18th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile:
415-834-9070
Attorneys for Defendant
NAVIENT SOLUTIONS, LLC f/k/a
NAVIENT SOLUTIONS, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA—SACRAMENTO

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Case No. 2:16-cv-02327-JAM-AC

SHERRI JOHNSON,
Plaintiff,

AMENDED STIPULATION TO EXTEND
TIME TO FILE REPLY AND
CONTINUE HEARING ON
DEFENDANT’S MOTION FOR
SUMMARY JUDGMENT AND
RELATED DATES

vs.
NAVIENT SOLUTIONS, INC.,
Defendant.

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Complaint Filed: September 29, 2016

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IT IS HEREBY STIPULATED AND AGREED by and between Plaintiff Sherri Johnson

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and Defendant Navient Solutions, LLC f/k/a Navient Solutions, Inc., through their respective

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attorneys of record, as follows:

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HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

WHEREAS, Mr. Lueck, lead counsel for Defendant, recently changed law firms from
Akerman LLP to Hinshaw & Culbertson LLP;
WHEREAS, the file for this matter has not yet been transmitted from Akerman LLP to
Hinshaw & Culbertson LLP;
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WHEREAS, Mr. Lueck is currently staffing this matter, and the other matters he has
transferred from Akerman LLP to Hinshaw & Culbertson;

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WHEREAS, the Reply In Support of Defendant’s Motion for Summary Judgment is
currently due September 26, 2017;

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WHEREAS, the hearing on Defendant’s Motion for Summary Judgment is currently set
for October 3, 2017;

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WHEREAS, the parties have agreed to extend the deadline for Defendant to file its reply
brief to October 31, 2017;

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WHEREAS, the parties have agreed to reschedule the hearing on Defendant’s Motion for
Summary Judgment for November 7, 2017;

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WHEREAS, pursuant to the Courts instruction, the parties must also reschedule the pretrial
statement due date, the pretrial conference date, and the trial date,

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WHEREAS, the parties agree that the parties’ joint pretrial statement shall be due no later
than January 19, 2018,

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WHEREAS, the parties agree that the pretrial conference is continued to January 26, 2018,
at 10:00 a.m.;

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WHEREAS, the parties agree that the trial date is continued to March 12, 2018, at 9:00
a.m.;
WHEREAS, this is Defendant’s first request for an extension of this deadline and
continuance of the hearing;

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WHEREFORE, the parties respectfully request that the Court enter an Order extending

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the deadline for Defendant to file its Reply in Support of its Motion for Summary Judgment to

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October 31, 2017; setting the hearing on Defendant’s Motion for Summary Judgment on

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November 7, 2017; setting the deadline to file the parties joint pretrial statement for January 19,

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2018; continuing the pretrial conference to January 26, 2018, at 10:00 a.m.; and continuing trial to

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March 12, 2018, at 9:00 a.m.

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HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

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300505548v1 1002164

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DATED:

September 28, 2017

Hinshaw & Culbertson LLP

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By: /s/Tyler A. Carle
Dennis N. Lueck, Jr.
Tyler A. Carle

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DATED:

September 28, 2017

Kimmel & Silverman, P.C.

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By: ./s/ Rachel R. Stevens
Rachel R. Stevens
Attorney for Plaintiff
Sherri Johnson

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I, Tyler A. Carle., am the ECF user whose identification and password are being used to
file this Stipulation. I hereby attest that Rachel R. Stevens has concurred in this filing.

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/s/Tyler A. Carle

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HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

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ORDER
Good cause having been shown, the Court approves the Stipulation and orders the
following:
1) The deadline for Defendant to file its Reply in Support of its Motion for Summary
Judgment to October 31, 2017;
2) The hearing on Defendant’s Motion for Summary Judgment is set for November 7, 2017
at 1:30 p.m.;

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3) The deadline to file the parties’ joint pretrial statement for January 19, 2018;

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4) The pretrial conference is continued to January 26, 2018, at 10:00 a.m.; and

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5) The trial date is continued to March 12, 2018, at 9:00 a.m.

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IT IS SO ORDERED

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DATED: 9/28/2017

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/s/ John A. Mendez___________________

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United States District Court Judge

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HINSHAW & CULBERTSON LLP
633 West 5th Street, 47th Floor
Los Angeles, CA 90071-2043
213-680-2800

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