Marcelos v. Dominguez et al

Filing 21

STIPULATION AND ORDER EXTENDING TIME IN WHICH NEW CENTURY TITLE COMPANY AND VIKI RAAB MAY RESPOND TO THE COMPLAINT. Signed by Judge Alsup on February 4, 2008. (whalc2, COURT STAFF) (Filed on 2/4/2008)

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Marcelos v. Dominguez et al Doc. 21 Case Case 3:08-cv-00056-WHA Document 19 21 Filed 02/01/2008 02/04/2008 Page 1 of 4 5 1 2 3 4 5 6 7 8 9 10 SHARTSIS FRIESE LLP ONE MARITIME PLAZA EIGHTEENTH FLOOR SAN FRANCISCO, CA 94111 SHARTSIS FRIESE LLP JOEL ZELDIN (Bar #51874) SIMONE M. KATZ (Bar #246490) One Maritime Plaza, Eighteenth Floor San Francisco, CA 94111 Telephone: (415) 421-6500 Facsimile: (415) 421-2922 Email: jzeldin@sflaw.com; skatz@sflaw.com Attorneys for Defendants VIKI RAAB AND NEW CENTURY TITLE COMPANY UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Pursuant to Local Rule 6-1(a), Plaintiff Ricardo Marcelos ("Plaintiff") and Defendants New Century Title Company ("New Century") and Viki Raab ("Raab"), by and through they respective counsel, all subject to the approval of this Court, hereby stipulate February 25, 2008 as the date by which New Century and Raab must answer or otherwise respond to the Complaint presently on file herein, based upon the following facts and circumstances: 1. Plaintiff filed his Complaint on January 4, 2008. Case No. CV 08-0056 WHA -1STIPULATION AND [PROPOSED] ORDER EXTENDING TIME IN WHICH NEW CENTURY TITLE COMPANY AND VIKI RAAB MAY RESPOND TO THE COMPLAINT Dockets.Justia.com RICARDO MARCELOS, Plaintiff, v. EDWIN MAURICIO PARADA DOMINGUEZ, GLENDA PARADA, LORENZO PARADA, VIKI RAAB, COUNTRYWIDE HOME LOANS, ARGENT MORTGAGE COMPANY, LLC, PRIMESTAR FINANCIAL SERVICES, SHOAIB MAHMUD, FINANCIAL TITLE COMPANY, NEW CENTURY TITLE COMPANY, RECONTRUST COMPANY, N.A., AND DOES 1 through 100, Defendants. Case No. CV08-0056 WHA STIPULATION AND [PROPOSED] ORDER EXTENDING TIME IN WHICH NEW CENTURY TITLE COMPANY AND VIKI RAAB MAY RESPOND TO THE COMPLAINT Judge: Complaint Filed: Hon. William H. Alsup January 4, 2008 Case Case 3:08-cv-00056-WHA Document 19 21 Filed 02/01/2008 02/04/2008 Page 2 of 4 5 1 2 3 4 5 6 7 8 9 10 SHARTSIS FRIESE LLP ONE MARITIME PLAZA EIGHTEENTH FLOOR SAN FRANCISCO, CA 94111 2. New Century was served with the Complaint and summons through its agent for service of process on January 15, 2008. 3. Raab has not yet been served with the Complaint and summons as of the date of this stipulation. 4. Raab is a former employee of New Century, but is no longer employed by New Century. 5. Counsel for New Century has agreed to represent Raab and to accept service on her behalf. 6. Starting on or about February 1, 2008, Raab will be out of the state for two weeks, and counsel for New Century and Raab would like to meet with her upon her return from vacation, before filing a responsive pleading. 7. The parties believe that judicial efficiency and economy will be promoted if New Century and Raab respond to the Complaint at the same time. 8. No prior extensions of time have been requested by New Century or Raab. 9. This extension does not alter the date of any event or any deadline already fixed by Court order. 10. Local Rule 6-1(a) does not require a Court order when the change in the date for a responsive pleading will not alter the date of any event or any deadline already fixed by Court order. 11. The parties nevertheless want to ensure that the extension of time is acceptable to the Court. Now therefore, based upon the foregoing, the parties hereto stipulate as follows: The time within which New Century and Raab may answer or otherwise respond to the Complaint is extended to and including February 25, 2008. /// /// /// 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case No. CV 08-0056 WHA -2STIPULATION AND [PROPOSED] ORDER EXTENDING TIME IN WHICH NEW CENTURY TITLE COMPANY AND VIKI RAAB MAY RESPOND TO THE COMPLAINT Case Case 3:08-cv-00056-WHA Document 19 21 Filed 02/01/2008 02/04/2008 Page 3 of 4 5 1 2 3 4 5 6 7 8 9 10 SHARTSIS FRIESE LLP ONE MARITIME PLAZA EIGHTEENTH FLOOR SAN FRANCISCO, CA 94111 DATED: January 31, 2008 SHARTSIS FRIESE LLP By: /s/ Simone M. Katz SIMONE M. KATZ Attorneys for Defendants VIKI RAAB AND NEW CENTURY TITLE COMPANY DATED: January 31, 2008 LIUZZI, MURPHY & SOLOMON, LLP By: /s/ Michael E. Hale MICHAEL E. HALE Attorneys for Plaintiff RICARDO MARCELOS 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case No. CV 08-0056 WHA -3STIPULATION AND [PROPOSED] ORDER EXTENDING TIME IN WHICH NEW CENTURY TITLE COMPANY AND VIKI RAAB MAY RESPOND TO THE COMPLAINT Case Case 3:08-cv-00056-WHA Document 19 21 Filed 02/01/2008 02/04/2008 Page 4 of 4 5 1 2 3 4 5 6 7 8 9 5982\004\SKATZ\1487230.1 ORDER Having read the foregoing stipulation of the Parties, and good cause appearing therefore, it is hereby ordered the time within which New Century and Raab may answer or otherwise respond to the Complaint is extended to and including February 25, 2008. UNIT ED ISTRIC ES D TC AT T RT U O PURSUANT TO STIPULATION, IT IS SO ORDERED. S ER N F D IS T IC T O R 10 SHARTSIS FRIESE LLP ONE MARITIME PLAZA EIGHTEENTH FLOOR SAN FRANCISCO, CA 94111 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Case No. CV 08-0056 WHA -4STIPULATION AND [PROPOSED] ORDER EXTENDING TIME IN WHICH NEW CENTURY TITLE COMPANY AND VIKI RAAB MAY RESPOND TO THE COMPLAINT A C LI HONORABLE WILLIAM H. ALSUP RT H FO February 4 Date: _____________________, 2008 Judge W illiam A lsup R NIA IT IS S O ORD ERED NO Casee3:08-cv-00056-WHA Document 19-2 Cas 3:08-cv-00056-WHA Document 21 Filed 02/04/2008 Page 51of 51 Filed 02/01/2008 Page of

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