Wang v. Asset Acceptance LLC

Filing 65

ORDER continuing cmc to 9/3/10 (tf, COURT STAFF) (Filed on 6/17/2010)

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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 Robert J. Schuckit, Esq. (IN #15342-49) (admitted Pro Hac Vice) Schuckit & Associates, P.C. 30th Floor, Market Tower 10 West Market Street, Suite 3000 Indianapolis, IN 46204 Telephone: 317-363-2400 Fax: 317-363-2257 E-Mail: rschuckit@schuckitlaw.com Lead Counsel for Defendant Trans Union, LLC Michael W. Bien, Esq. (CSB #96891) Mark R. Feeser, Esq. (CSB # 252968) Rosen, Bien & Galvan, LLP 315 Montgomery Street, Tenth Floor San Francisco, CA 94104 Telephone: 415-433-6830 Fax: 415-433-7104 E-Mail: mbein@rbg-law.com mfeeser@rbg-law.com Local Counsel for Defendant Trans Union, LLC UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION ) ) ) ) ) ) ) ) ) ) ) CASE NO. 3:09-cv-04797-SI STIPULATION AND [PROPOSED] ORDER FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE JOHNNY WANG, an individual, on his own behalf and on behalf of others similarly situated, Plaintiffs, vs. ASSET ACCEPTANCE, LLC, and TRANS UNION, LLC, Delaware limited liability companies, and DOES 1-100, inclusive, Defendants. Plaintiff Johnny Wang, an individual, on his own behalf and on behalf of all others similarly situated , pursuant to STIPULATION AND [PROPOSED] ORDER FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE 3:09-CV-04797-SI Page 1 of 4 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 Local Rule 7.12 hereby submit their Stipulation And [Proposed] Order For Continuance of the In support of the Stipulation, the Parties state: 1. By Order dated April 23, 2010, the Initial Case Management Conference in this cause is currently set for Friday, July 9, 2010, at 2:30 p.m. 2. The deadline of June 29, 2010, to request that the Court reschedule the Initial Case Management Conference has not passed. 3. Defendant Trans Union became a party to this action when it was served with the Amended Complaint on or about May 11, 2010, and filed its Answer on May 28, 2010. 4. m eanin,gfully in the Conference required by Feder in drafting the Joint Case Management Statement as required by Local Rule 16-9(a) and in participating in the Initial Case Management Conference as well as any Court-ordered mediation of this case pursuant to ADR Local Rule 6, the Parties agree that an additional eight (8) weeks, or until September 3, 2010, is necessary for the Parties to prepare properly for the Rule 26(f) Conference, to discuss how to integrate Trans Union into the pending proceedings and to prepare for any Court-ordered mediation. 5. This Stipulation is not made for the purposes of delay and would not prejudice Trans Union has made a good faith effort to review the facts and allegations of any party. This Stipulation does not prevent or stay discovery or motion practice. STIPULATION AND [PROPOSED] ORDER FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE 3:09-CV-04797-SI Page 2 of 4 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 SO STIPULATED by: Date: June 15, 2010 s/Robert J. Schuckit Robert J. Schuckit, Esq. (IN #15342-49) (admitted Pro Hac Vice) Schuckit & Associates, P.C. 30th Floor, Market Tower 10 West Market Street, Suite 3000 Indianapolis, IN 46204 Telephone: 317-363-2400 Fax: 317-363-2257 E-Mail: rschuckit@schuckitlaw.com Lead Counsel for Defendant Trans Union, LLC Date: June 15, 2010 s/Ethan Preston (with consent) Ethan Preston, Esq. (263295) Preston Law Offices 1658 North Milwaukee Avenue, No. 253 Chicago, IL 60622 Telephone: 312-492-4070 Fax: 312-262-1007 E-Mail: ep@eplaw.us Lead Counsel for Plaintiff Johnny Wang, et al. Date: June 15, 2010 s/Tomio Buck Narita (with consent) Tomio Buck Narita, Esq. Jeffrey A. Topor, Esq. Simmonds & Narita, LLP 44 Montgomery Street, Suite 3010 San Francisco, CA 94104-4816 Telephone: 415-283-1000 Fax: 415-352-2625 E-Mail: tnarita@snllp.com E-Mail: jtopor@snllp.com Lead Counsel for Defendant Asset Acceptance, LLC STIPULATION AND [PROPOSED] ORDER FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE 3:09-CV-04797-SI Page 3 of 4 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 STIPULATION AND [PROPOSED] ORDER FOR CONTINUANCE OF CASE MANAGEMENT CONFERENCE 3:09-CV-04797-SI Page 4 of 4 [PROPOSED] ORDER Pursuant to the Stipulation of the Parties and for good cause there appearing, IT IS HEREBY ORDERED as follows: 1. The Initial Case Management Conference currently scheduled for Friday, July 9, 2010, at 2:30 p.m., is hereby CONTINUED to Friday, September 3, 2010, at 2:30 p.m., to allow the Parties sufficient time to prepare for said Conference and for all other matters preparatory to same. This Order does not prevent or stay discovery or motion practice. 2. 1, 2010. The time within which mediation must take place is EXTENDED until November PURSUANT TO STIPULATION, IT IS SO ORDERED. Dated: ___________________________ ___________________________________ Hon. Susan Illston, Judge U.S. District Court Northern District of California

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