Sarique et al v. Bank of America, N.A. et al

Filing 19

STIPULATION AND ORDER RESCHEDULING CASE MANAGEMENT CONFERENCE. Joint updated Case Management Statement due by 1/20/2012. Case Management Conference set for 1/27/2012 01:30 PM in Courtroom G, 15th Floor, San Francisco. Signed by Judge Joseph C. Spero on 10/31/11. (klhS, COURT STAFF) (Filed on 11/1/2011)

1 LAW OFFICES OF KENNETH R. GRAHAM
Kenneth R. Graham, SB #216733

2 1575 Treat Blvd., Suite 105
Walnut Creek, CA 94598

3 Tel: [phone]
Fax: [phone]

4 Email: [e-mail]
Attorneys for Plaintiff

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Bryan Cave LLP
Two Embarcadero Center, Suite 1410
San Francisco, CA 94111-3907

BRYAN CAVE LLP

6 C. Scott Greene California Bar No. 277445
Tracy M. Talbot, California Bar No. 259786
7 Edward Chung, California Bar No. 256616
Two Embarcadero Center, Suite 1410
8 201 Clay Street
San Francisco, CA 94111-3907
9 Telephone: [phone]
Facsimile: [phone]
[e-mail]
10 Email:
tracy.talbot @bryancave.com
chunge@bryan cave.com
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Attorneys for Defendants Bank of America, N.A. and PRLAP, Inc.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SARIQUE, ELGIN AND DAISY, individuals,

Case No. 3:11-cv-03641-JCS

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Plaintiffs,

HON. JOSEPH C. SPERO

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v.

JOINT STIPULATION RESCHEDULING
CASE MANAGEMENT CONFERENCE;
[PROPOSED] ORDER

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BANK OF AMERICA, N.A. (A.K.A. BANK

20 OF AMERICA HOME LOANS), a
Corporation, NATIONAL BANK

[L.R. 6-1(a)]

21 ASSOCIATION, a Corporation; PRLAP
INC., a Corporation; and DOES 1 through 50,

22 inclusive,
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Defendants.

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SF01DOCS\50469.1

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JOINT STIPULATION RESCHEDULING CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER

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STIPULATION

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Defendants Bank of America, N.A. and PRLAP, Inc. (“Defendants”), and Plaintiffs Elgin

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Sarique and Daisy Sarique (“Plaintiffs”), by and through their counsel of record, hereby stipulate

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and agree as follows:

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1.

Defendants Bank of America, N.A. and PRLAP, Inc. removed this matter from

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Santa Clara County Superior Court on July 25, 2011.

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2.

The parties previously stipulated to two extensions for Defendants to respond to the

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Complaint 15 days to August 16, 2011 and then 60 days to October 17, 2011.

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Bryan Cave LLP
Two Embarcadero Center, Suite 1410
San Francisco, CA 94111-3907

3.

The parties then stipulated for Defendants to respond to the Complaint no later than

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January 18, 2012.

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4.

A Case Management Conference is scheduled for November 4, 2011.

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The parties agree that a Case Management Conference on this date would be

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premature in light of current settlement discussions and the fact that Defendants have not yet

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responded to the Complaint.

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6.

The parties agree to continue the Case Management Conference to a date after

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January 18, 2012, the deadline for Defendants to respond to the Complaint.

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7.

The parties believe that the later case management conference will prevent

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unnecessary consumption of expense and time to both the parties and judicial resources.

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8.

The stipulation will not result in prejudice to any party and its impact on judicial

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proceedings is not expected to be significant.

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9.

Nothing in this stipulation shall constitute a waiver of any arguments or defenses

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that Defendants or Plaintiffs may wish to assert in their pleadings, all of which are expressly

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reserved.

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///

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SF01DOCS\50469.1

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JOINT STIPULATION RESCHEDULING CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER

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IT IS SO STIPULATED.

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Dated: October 28, 2011

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LAW OFFICES OF KENNETH GRAHAM

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By:

/s/ Kenneth R. Graham
Kenneth R. Graham
Attorney for Plaintiffs
ELGIN SARIQUE and DAISY SARIQUE

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Bryan Cave LLP
Two Embarcadero Center, Suite 1410
San Francisco, CA 94111-3907

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9 Dated: October 28, 2011
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BRYAN CAVE LLP
C. Scott Green
Tracy M. Talbot
Edward Chung
By:

/s/ Edward Chung
Edward Chung
Attorneys for Defendants
BANK OF AMERICA, N.A. and PRLAP, INC.

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SF01DOCS\50469.1

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JOINT STIPULATION RESCHEDULING CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER

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[PROPOSED] ORDER
Having reviewed the stipulation of Plaintiffs ELGIN SARIQUE and DAISY SARIQUE

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IT IS HEREBY ORDERED that the Case Management Conference is rescheduled to

January 27, 2012 at 1:30
5 ____________________. p.m. An updated joint cmc statement shall be due by Jan. 20, 2012.

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________________________________
RDERE
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ISC.O O FIED
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Judge Joseph MODI
Spero
AS
United States District Court
Northern District ofpCalifornia
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Bryan Cave LLP
Two Embarcadero Center, Suite 1410
San Francisco, CA 94111-3907

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UNIT
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10/31/11
8 Dated: ____________

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SF01DOCS\50469.1

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JOINT STIPULATION RESCHEDULING CASE MANAGEMENT CONFERENCE; [PROPOSED] ORDER