Sterling Savings Bank v. Poulsen

Filing 51

ORDER by Magistrate Judge Elizabeth D. Laporte granting 49 Modified Stipulation to Extend Deadlines. (rmm2S, COURT STAFF) (Filed on 1/11/2013)

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BETTY M. SHUMENER (Bar No. 137220)
HENRY H. OH (Bar No. 187127)
JOHN D. SPURLING (Bar No. 252324)
SHUMENER, ODSON & OH LLP
550 South Hope Street, Suite 1050
Los Angeles, CA 90071-2678
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff,
STERLING SAVINGS BANK

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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STERLING SAVINGS BANK, a
Washington corporation, Successor In
Interest by Merger to SONOMA
NATIONAL BANK,

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Case No. 3:12-cv-01454-EDL

Plaintiff,

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STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINES
AS MODIFIED

v.
NORMAN POULSEN, aka LISA
POULSEN, an individual; and DOES 1
through 10, inclusive,

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Defendants.

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SHUMENER,
ODSON & OH LLP

CASE NO. CV 12-1454-EDL

STIPULATION TO EXTEND DEADLINES

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STIPULATION
IT IS HEREBY STIPULATED by and between plaintiff Sterling Savings Bank

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("Plaintiff') and defendant Lisa Poulsen, aka Norman Poulsen ("Defendant"), through their

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respective counsel of record, as follows:

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WHEREAS, this Court entered a Case Management and Pretrial Order for Jury Trial for
this action on October 3, 2013, which set forth the following dates and deadlines:

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1.

Jury trial to begin on June 17, 2013;

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2.

All non-expert discovery to be completed no later than February 1, 2013;

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3.

Initial expert disclosures to be made no later than March 15, 2013;

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4.

Rebuttal expert disclosures to be made no later than March 29, 2013;

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5.

All expert discovery to be completed no later than April 16, 2013;

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6.

The last day to file a motion, or stipulation and proposed order, to join other

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parties or to amend the pleadings was January 2, 2013;

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7.

The last day for hearing dispositive motions is March 19, 2013;

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8.

Mediation proceedings are to be completed by December 26, 2012 (within 90 days

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of the order), or as soon thereafter as possible; and

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9.

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WHEREAS, both Plaintiff and Defendant have been diligent in conducting discovery, and

A pretrial conference is to be held on May 28, 2013;

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agree that additional time is needed to complete written discovery and depositions necessary for

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the adjudication of this case;

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WHEREAS, the parties commenced mediation on December 4, 2012, and are currently

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engaged in ongoing mediation and settlement discussions, and agree that it is in the best interest

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of both Plaintiff and Defendant to undergo further settlement negotiations with the mediator;

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WHEREAS, the parties agree that extending the deadlines for discovery, dispositive

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motions and trial by approximately sixty (60) days would benefit the parties' settlement

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discussions;

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SHUMENER,
ODSON & OH LLP

-2CASE NO. CV 12-1454-EDL

STIPULATION TO EXTEND DEADLINES

NOW, THEREFORE, the parties hereby agree and stipulate:
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1.

Plaintiff and Defendant agree and stipulate that the current schedule for this case,

as set forth in this Court's Case Management and Pretrial Order for Jury Trial filed October 3,
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2012, be modified as follows:

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a.

Jury trial is to begin on October 7, 2013;

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b.

All non-expert discovery must be completed no later than April 1, 2013;

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c.

Initial expert disclosures must be made no later than May 17, 2013;

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d.

Rebuttal expert disclosures must be made no later than May 31, 2013;

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e.

All expert discovery must be completed no later than June 30, 2013;

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f.

The last day to file a motion, or stipulation and proposed order, to join other

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parties or to amend the pleadings is March 1, 2013;

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g.

The last day for hearing dispositive motions is July 15, 2013;

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h.

Mediation proceedings are to be completed by March 1, 2013, or as soon thereafter

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as possible; and

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i.

A pretrial conference is to be held on September 16, 2013;

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2.

The parties respectfully request that the Court modify the time frames set forth in

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the aforementioned Case Management and Pretrial Order to reflect the dates and deadlines

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provided in the preceding paragraph;

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3.

Plaintiff and Defendant have reviewed, agree and consent to the entry of the

Proposed Order to Extend Deadlines.
IT IS SO STIPULATED:
DATED: January 7, 2013

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SHUMENER, ODSO OH LLP

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By:

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SAVINGS BANK

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-2-

SHUMENER,
ODSON & OH LLP

CASE NO, CV I2-1454-EDL

STIPULATION TO EXTEND DEADLINES

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DATED: January 7, 2013

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DOHERTY GEORGESON LLP

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By:
Adamont N. Geo.
Attorneys for Defe ant
LISA POULSEN

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SIIUMENER,
ODSON & OH LLP

CASE NO. CV 12-1454-EDL

STIPULATION TO EXTEND DEADLINES

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ORDER

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PURSUANT TO STIPULATION, IT IS SO ORDERED:

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1.

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The current schedule for this case, as set forth in the Case Management and

Pretrial Order for Jury Trial entered October 3, 2012, shall be modified as follows:

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a.

Jury trial is to begin on October 7, 2013;

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b.

All non-expert discovery must be completed no later than April 1, 2013;

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c.

Initial expert disclosures must be made no later than May 17, 2013;

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d.

Rebuttal expert disclosures must be made no later than May 31, 2013;

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e.

All expert discovery must be completed no later than June 30, 2013;

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f.

The last day to file a motion, or stipulation and proposed order, to join other

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parties or to amend the pleadings is March 1, 2013;

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g.

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The last day for hearing dispositive motions is July 15, 2013;

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h.

Mediation proceedings are to be completed by March 1, 2013, or as soon

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thereafter as possible; and

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A pretrial conference is to be held on September 16, 2013;

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i.

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IT IS SO ORDERED.

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Dated: January 10, 2013

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Elizabeth D. Laporte
Magistrate Judge of the United States District
Court, Northern District of California

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-4-

SHUMENER,
ODSON & OH LLI'

CASE NO. CV 12-1454-EDL

[PROPOSED] ORDER TO EXTEND DEADLINES

PROOF OF SERVICE

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STATE OF CALIFORNIA, COUNTY OF LOS ANGELES
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I am employed in the City of Los Angeles, in the County of Los Angeles, State of
California. I am over the age of 18 and not a party to the within action. My business address is
550 South Hope Street, Suite 1050, Los Angeles, CA 90071.

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On, January 9, 2013 I served the foregoing document(s) described as follows:
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STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINES
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on the interested parties in this action by delivering a true copy thereof enclosed in a sealed
envelope addressed as follows:

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Adamont N. Georgeson
Doherty Georgeson LLP
1101 Fifth Avenue, Suite 310
San Rafael, CA 94901
[e-mail]

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(BY MAIL) I deposited such envelope in the mail at Los Angeles California. The
envelope was mailed with postage thereon fully prepaid. I am readily familiar with the
firm's practice for collection and processing correspondence for mailing. Under that
practice, this document will be deposited with the U.S. Postal Service on this date with
postage thereon fully prepaid at Los Angeles, California in the ordinary course of
business. I am aware that on motion of the party served, service is presumed invalid if
postal cancellation date or postage meter date is more than one day after date of deposit
for mailing in affidavit.

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(BY OVERNIGHT DELIVERY/COURIER) I delivered an envelope or package to a
courier or driver authorized by the express service carrier; or deposited such envelope or
package to a regularly maintained drop box or facility to receive documents by the
express service carrier with delivery fees provided for.

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[]
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(BY MESSENGER) I served the document(s) to the person(s) at the address(es) listed
by providing the document(s) to a messenger for personal service. (A proof of service
executed by the messenger will be filed in compliance with the Code of Civil Procedure).

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[X] (BY ELECTRONIC MAIL) As follows: I caused the above-referenced documents(s)
to be transmitted by electronic mail to its intended recipient(s) through ECF at the e-mail
addresses indicated above.

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[

(BY PERSONAL SERVICE) I delivered the foregoing document(s) by hand to the
office(s) of the addressee(s).

[X] (FEDERAL) I declare that I am employed in the office of a member of the bar of this
Court at whose direction service was made.

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Executed on January 9, 2013, at Los Angeles, CA.
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Donna Holland

PROOF OF SERVICE