County of San Mateo v. Bank of America, N.A. et al

Filing 46

ORDER CONTINUING DATE FOR CASE MANAGEMENT CONFERENCE. The Case Management Conference is continued from January 30, 2009 to March 27, 2009. Signed by Judge Maxine M. Chesney on January 14, 2009. (mmclc1, COURT STAFF) (Filed on 1/14/2009)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 REGINALD D. STEER (SBN 056324) E-mail: rsteer@akingump.com STEVEN S. KAUFHOLD (SBN 157195) E-mail: skaufhold@akingump.com AMIT KURLEKAR (SBN 244230) E-mail: akurlekar@akingump.com TERESA WANG (SBN 252961) E-mail: twang@akingump.com AKIN GUMP STRAUSS HAUER & FELD LLP 580 California Street, 15th Floor San Francisco, California 94104-1036 Telephone: 415-765-9500 Facsimile: 415-765-9501 Attorneys for Defendants AIG FINANCIAL PRODUCTS CORP. and AIG SUNAMERICA LIFE ASSURANCE COMPANY UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA COUNTY OF SAN MATEO, Plaintiff, v. STIPULATION AND [PROPOSED] ORDER CONTINUING DATE FOR CASE MANAGEMENT CONFERENCE Case No. CV 08-04751 MMC BANK OF AMERICA, N.A., et al. Defendants. Pursuant to Civil Local Rules 6-2 and 7-12, this stipulation is entered into by and between plaintiff COUNTY OF SAN MATEO (the "County") and defendants AIG FINANCIAL PRODUCTS CORP. and AIG SUNAMERICA LIFE ASSURANCE COMPANY (the "AIG Defendants") through their respective counsel of record, based upon the following: WHEREAS, in a stipulation filed on December 12, 2008 with this Court, the parties stipulated that no defendant need respond before March 16, 2009, to the amended complaint filed by plaintiffs on November 24, 2008, WHEREAS, although the consent of defendants other than the AIG Defendants is not required because no defendant's position is compromised by this Stipulation, counsel for the AIG Defendants 1 STIPULATION AND [PROPOSED] CONTINUING DATE FOR CASE MANAGEMENT CONFERENCE Case No. CV 08 04751 MMC 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 can nevertheless report that identified counsel for the other defendants that have appeared in this action have been canvassed and all support the Court's approval of this Stipulation; NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between the parties, and the parties jointly move as follows: 1. That the Court extend the date for the case management conference, originally scheduled for Friday, January 30, 2009, to Friday, March 27, 2009, 2. That the deadlines for submitting the case management conference statement, Rule 26(f) report, initial closures, the Alternative Dispute Resolution ("ADR") certificate and ADR stipulation or Notice of Need for ADR phone conference, and any other documents with deadlines dependent on the case management conference date be continued accordingly, and 3. No defense of any defendant to this action is prejudiced or waived by its submission of this Stipulation, including but not limited to assertion of jurisdictional defenses. 4. Defense counsel may file notices of appearance in this action without prejudice to their respective clients' jurisdictional and venue defenses. The parties have previously stipulated that no defendant need respond to the County's amended complaint before March 16, 2009. Dkt. No. 38. Thus, the parties believe that scheduling the case management conference after that date will not adversely affect the scheduling in the case. IT IS SO STIPULATED. Dated: January 12, 2009 AKIN GUMP STRAUSS HAUER & FELD LLP By /s/ Reginald D. Steer Attorneys for Defendants AIG FINANCIAL PRODUCTS CORP. and AIG SUNAMERICA LIFE ASSURANCE COMPANY Dated: January 12, 2009 COTCHETT, PITRE, & MCCARTHY By /s/ Nanci E. Nishimura Attorneys for Plaintiff COUNTY OF SAN MATEO 2 STIPULATION AND [PROPOSED] CONTINUING DATE FOR CASE MANAGEMENT CONFERENCE Case No. CV 08 04751 MMC 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 PURSUANT TO STIPULATION, IT IS SO ORDERED January 14, 2009 Dated: _________________ ______________________________________ Hon. Maxine M. Chesney 3 STIPULATION AND [PROPOSED] CONTINUING DATE FOR CASE MANAGEMENT CONFERENCE Case No. CV 08 04751 MMC

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