Raass et al v. Bank of America, National Association et al

Filing 6

ORDER APPROVING STIPULATION TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE. The Case Management Conference is continued from April 30, 2010 to June 11, 2010. Signed by Judge Maxine M. Chesney on April 26, 2010. (mmclc1, COURT STAFF) (Filed on 4/26/2010)

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Renée Welze Livingston (SBN 124280) Jason G. Gong (SBN 181298) LIVINGSTON LAW FIRM A Professional Corporation 1600 South Main Street, Suite 280 Walnut Creek, CA 94596 Tel: [phone] Fax: [phone] Attorneys for Defendant FEDERAL DEPOSIT INSURANCE CORPORATION as Receiver for INDYMAC BANK, F.S.B. UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA ) ) ) Plaintiffs, ) ) vs. ) ) BANK OF AMERICA, NATIONAL ) ASSOCIATION, a United States ) Corporation; COUNTRYWIDE, a ) California Corporation; INDYMAC BANK, ) a California Corporation; MORTGAGE ) ELECTRONIC REGISTRATION ) SYSTEMS, INC., a California Corporation; ) QUALITY LOAN SERVICE ) CORPORATION; and DOES 1 through 10, ) inclusive, ) ) ) Defendants. ) EDWARD RAASS AND EVELINI RAASS, Case No. 3:10-cv-00187-MMC STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND ORDER THEREON Complaint Filed: 09/21/09 Trial Date: None

Defendant FEDERAL DEPOSIT INSURANCE CORPORATION, as Receiver for IndyMac Bank, F.S.B. ("FDIC"), and Plaintiffs EDWARD RAASS and EVELINI RAASS, by and through their respective counsel, respectfully request and make the following stipulation: 1. Whereas, the parties have had on-going discussions regarding the underlying

issues presented in this action to evaluate whether informal resolution of the matter is possible; 2. Whereas, the Court's January 14, 2010 order setting Initial Case Management

Conference and ADR Deadlines presently requires the parties to meet their respective obligations
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Raass v. Bank of America, et al. Case No. 3:10-cv-00187-MMC Stipulation and [Proposed] Order Continuing Initial Case Management Conference. 1

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under Rule 26(f) of the Federal Rules of Civil Procedure ("Fed. R. Civ. P.") and applicable Local Rules of this Court in preparation for the Court's Initial Case Management Conference ("Initial CMC") currently set for April 30, 2010 at 10:30 a.m. before this Court; 3. Whereas, the parties will benefit from additional time to determine whether a

settlement of this matter can be reached upon mutually agreeable terms and conditions; 4. Whereas, the parties believe it would be in the interests of the parties and of this

Court to continue the Initial CMC for a period of forty-two (42) days until June 11, 2010 to allow the parties to reach a settlement of this case; IT IS STIPULATED: That the parties' obligations under Fed. R. Civ. P. 26(f) and the Local Rules of this Court are continued in accordance to the Court's assignment of June 11, 2010 as the new date for the Initial CMC. Respectfully submitted, Dated: April 23, 2010 LIVINGSTON LAW FIRM /s/ Jason G. Gong By: _____________________________________ Jason G. Gong Attorneys for defendant FEDERAL DEPOSIT INSURANCE CORPORATION, as Receiver for INDYMAC FEDERAL BANK Dated: April 23, 2010 LAW OFFICES OF MICHAEL MOGHTADER /s/ Michael Moghtader By: ____________________________________ Michael Moghtader Attorney for Plaintiffs EDWARD RAASS And EVELINI RAASS

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Raass v. Bank of America, et al. Case No. 3:10-cv-00187-MMC Stipulation and [Proposed] Order Continuing Initial Case Management Conference. 2

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ORDER IT IS HEREBY ORDERED that the Initial Case Management Conference currently set for April 30, 2010 is CONTINUED for a period of forty-two (42) days until June 11, 2010 at 10:30 a.m.

Honorable Maxine M. Chesney UNITED STATES DISTRICT JUDGE

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Raass v. Bank of America, et al. Case No. 3:10-cv-00187-MMC Stipulation and [Proposed] Order Continuing Initial Case Management Conference. 3