Ferrucci et al v. Bank of America, NA et al

Filing 62

STIPULATION and ORDER signed by District Judge John A. Mendez on 05/06/22 GRANTING the parties an additional 30 days from the date of this order to file dispositional documents in accordance with the provisions of Local Rule 160.(Licea Chavez, V)

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Cheryl O’Connor (State Bar No. 173897)
[e-mail]
Matthew T. Billeci (State Bar No. 329014)
[e-mail]
JONES DAY
3161 Michelson Drive, Suite 800
Irvine, CA 92612.4408
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
EXPERIAN INFORMATION SOLUTIONS, INC.

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UNITED STATES DISTRICT COURT

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EASTERN DISTRICT OF CALIFORNIA

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PERRY J. FERRUCCI AND BETSY P.
FERRUCCI,

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Hon. John A. Mendez

Plaintiffs,

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Case No. 2:20-cv-01043-JAM-KJN

v.
BANK OF AMERICA, N.A.; EQUIFAX
INFORMATION SERVICES, LLC;
EXPERIAN INFORMATION SOLUTIONS,
INC.,

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STIPULATION AND ORDER RE:
EXTENSION OF DEADLINE TO FILE
DISPOSITION DOCUMENTS
Complaint filed: May 21, 2020

Defendants.

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Plaintiffs Perry Ferrucci and Betsy P. Ferrucci along with the Defendant Experian

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Information Solutions, Inc. (“Experian”), pursuant to Local Rule 160(d), hereby stipulate and

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agree that good cause exists for extending the deadline by which to file disposition documents by

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thirty (30) days.

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1.

Plaintiffs filed a notice of settlement on February 2, 2022. (ECF No. 55).

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2.

That same day, the Court ordered the Parties to file dispositional documents within

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sixty (60) days in accordance with Local Rule 160. (ECF No. 56).
3.

On April 4, 2022, the Parties filed a stipulation seeking an extension of thirty (30)

days to file the disposition documents. (ECF. No. 59). The Court granted the stipulation on April

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STIPULATION AND ORDER RE: EXTENSION
OF DEADLINE
Case No. 2:20-cv-01043-JAM-KJN

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5, 2022. (ECF. No. 60).
4.

The Parties have agreed to the terms of the final settlement agreement. The lone

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remaining item is for Experian to distribute the settlement payment to Plaintiff. Within three

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business days of receiving the payment, Plaintiff will file the disposition documents.

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5.

The Parties believe that allowing a thirty (30) day extension will serve the ends of

judicial economy.
6.

The Parties have agreed to seek this extension for good cause, in good faith, and

not for the purpose of delay. The Parties do not anticipate any need to request additional time
beyond the thirty (30) day period requested herein.

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7.

Accordingly, the Parties jointly stipulate to and request of this Honorable Court

that it grant a thirty (30) day extension to file disposition documents.
WHEREFORE, Plaintiff and Experian pray that this Court extend the above-referenced
deadline and execute the proposed Order regarding the same, which is filed herewith, and for all
other just and appropriate relief.

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Dated: May 6, 2022
JONES DAY

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By: /s/ Matthew T. Billeci
Matthew T. Billeci

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Attorneys for Defendant
EXPERIAN INFORMATION SOLUTIONS,
INC.

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ZEMEL LAW, LLC

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By: /s/ Daniel Zemel
Daniel Zemel, Esq.
Attorney for Plaintiff
PERRY J. FERRUCCI and BETSY P.
FERRUCCI

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STIPULATION AND ORDER RE: EXTENSION
OF DEADLINE
Case No. 2:20-cv-01043-JAM-KJN

ORDER

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PURSUANT TO THE PARTIES’ STIPULATION, IT IS HEREBY ORDERED that the

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parties shall have an additional thirty (30) days from the date of this order to file dispositional

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documents in accordance with the provisions of Local Rule 160.

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Dated: May 6, 2022

/s/ John A. Mendez
THE HONORABLE JOHN A. MENDEZ
UNITED STATES DISTRICT COURT JUDGE

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STIPULATION AND ORDER RE: EXTENSION
OF DEADLINE
Case No. 2:20-cv-01043-JAM-KJN