Medford v. U.S. Bank National Association, et al.,

Filing 14

STIPULATION and ORDER signed by District Judge Morrison C. England, Jr. on 7/17/2018 EXTENDING the fact discovery cutoff to 4/25/2019. All deadlines set forth in the Court's Initial Pretrial Scheduling Order shall be amended accordingly. (York, M)

1 BRYAN CAVE LEIGHTON PAISNER LLP
Tracy M. Talbot, California Bar No. 259786
2 Alexandra C. Whitworth, California Bar No. 303046
Three Embarcadero Center, 7th Floor
3 San Francisco, CA 94111-4070
Telephone: [phone]
4 Facsimile: [phone]
E-Mail: [e-mail]
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Attorneys for Defendants
6 U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR CMALT REMIC 2006A2, REMIC PASS-THROUGH CERTIFICATES, SERIES 2006-A2; CITIMORTGAGE,
7 INC.; and CITICORP MORTGAGE SECURITIES, INC.
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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

BRYAN CAVE LEIGHT ON PAISNER LLP
THREE EMBA RCADER O CENTER, 7TH FLOO R
SAN FRANCISC O, CA 94111 -4070

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(SACRAMENTO COURTHOUSE)
DEBRA LYNN MEDFORD,
Plaintiff,

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v.

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U.S. BANK NATIONAL ASSOCIATION,
15 AS TRUSTEE FOR CMALT REMIC
2006-A2, REMIC PASS-THROUGH
16 CERTIFICATES, SERIES 2006-A2;
CITIMORTGAGE, INC.; CITICORP
17 MORTGAGE SECURITIES, INC.;
NORTHWEST TRUSTEE SERVICES,
18 INC.; and DOES 1 through 20 inclusive,

Case No.: 2:17-cv-01783
STIPULATION AND ORDER FOR
EXTENSION OF DISCOVERY
CUTOFF AND RELATED
DEADLINES

Complaint Filed: June 29, 2017
Removed:
August 25, 2017
Trial Date:
Not Assigned

Defendants.

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11934869.1

STIPULATION RE DISCOVERY CUTOFF

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IT IS HEREBY STIPULATED by and between Plaintiff DEBRA LYNN

2 MEDFORD (“Plaintiff”) and Defendants U.S. BANK NATIONAL ASSOCIATION, AS
3 TRUSTEE FOR CMALT REMIC 2006-A2, REMIC PASS-THROUGH CERTIFICATES,
4 SERIES 2006-A2; CITIMORTGAGE, INC.; and CITICORP MORTGAGE
5 SECURITIES, INC. (“Defendants”) (collectively, “the Parties”) as follows:
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1.

On August 25, 2017, the Court issued its Initial Pretrial Scheduling Order

7 (“Scheduling Order”);
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2.

On September 25, 2017, Defendants filed a Motion to Dismiss the Complaint

9 of Plaintiff (“the Motion”);
BRYAN CAVE LLP
THREE EMBA RCADER O CENTER, 7TH FLOO R
SAN FRANCISC O, CA 94111 -4070

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3.

The Motion has been fully briefed since December 6, 2017;

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4.

The Court has not issued any ruling on the Motion;

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5.

To avoid incurring unnecessary costs in the event the Motion is granted and

13 the Complaint is dismissed, the Parties have not yet engaged in discovery;
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6.

According to the Scheduling Order, all non-expert discovery is to be

15 completed by August 25, 2018, and further deadlines regarding expert discovery,
16 dispositive motions, and trial are triggered from the August 25, 2018 fact discovery cutoff;
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7.

Given the status of the currently pending Motion (which, if granted, would

18 dispose of the case), the Parties wish to extend the discovery cutoff and all deadlines
19 triggered therefrom, including expert discovery and dispositive motion deadlines;
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8.

To that end, the Parties agree that, with the Court’s permission, the

21 Scheduling Order should be vacated or amended, and the fact discovery cutoff should be
22 extended at least eight months, through and including April 25, 2019;
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9.

The Parties further agree that all deadlines triggered from the fact discovery

24 cutoff (e.g., expert discovery and dispositive motions) should be extended accordingly.
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IT IS SO STIPULATED.

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11934869.1

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STIPULATION RE DISCOVERY CUTOFF

1 Dated:

July 5, 2018

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BRYAN CAVE LEIGHTON PAISNER LLP
Tracy M. Talbot
Alexandra C. Whitworth

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By: /s/ Alexandra C. Whitworth
Alexandra C. Whitworth
Attorneys for Defendants
U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE FOR CMALT REMIC 2006-A2,
REMIC PASS-THROUGH CERTIFICATES,
SERIES 2006-A2; CITIMORTGAGE, INC.; and
CITICORP MORTGAGE SECURITIES, INC.

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9 Dated:

July 5, 2018

BRYAN CAVE LLP
THREE EMBA RCADER O CENTER, 7TH FLOO R
SAN FRANCISC O, CA 94111 -4070

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LAW OFFICES OF JASON ESTAVILLO
Jason W. Estavillo
Caitlin Phair

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By: /s/ Caitlin Phair
Caitlin Phair
Attorneys for Plaintiff
DEBRA LYNN MEDFORD

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16 I, Alexandra Whitworth, hereby attest that that concurrence in this filing has been obtained
17 from each of the other Signatories.
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By: /s/ Alexandra C. Whitworth
Alexandra C. Whitworth

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11934869.1

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STIPULATION RE DISCOVERY CUTOFF

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ORDER
Pursuant to the stipulation of the Parties, and for good cause showing, IT IS

3 HEREBY ORDERED that the fact discovery cutoff shall be extended to not later than
4 April 25, 2019, and all deadlines set forth in the Court’s Initial Pretrial Scheduling Order
5 shall be amended accordingly.
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IT IS SO ORDERED.

7 Dated: July 17, 2018
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BRYAN CAVE LLP
THREE EMBA RCADER O CENTER, 7TH FLOO R
SAN FRANCISC O, CA 94111 -4070

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11934869.1

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STIPULATION RE DISCOVERY CUTOFF