Behjou v. Bank of America Corporation

Filing 23

ORDER 21 STIPULATION WITH PROPOSED ORDER Second Joint Stipulation to Extend Case Management Conference filed by Bank of America Corporation. Case Management Conference reset for 12/7/2012 08:30 AM in Courtroom 6, 17th Floor, San Francisco.. Signed by Judge Charles R. Breyer on 8/6/2012. (beS, COURT STAFF) (Filed on 8/6/2012)

1 HANSON BRIDGETT LLP
RAYMOND F. LYNCH, SBN 119065
2 [e-mail]
SARAH D. MOTT, SBN 148597
3 [e-mail]
JANE M. FEDDES, SBN 282117
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425 Market Street, 26th Floor
5 San Francisco, California 94105
Telephone:
[phone]
6 Facsimile:
[phone]
7 Attorneys for Defendant
BANK OF AMERICA CORPORATION
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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12 OMID BEHJOU,

CASE NO. CV 12 1590 CRB

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SECOND JOINT STIPULATION TO
EXTEND CASE MANAGEMENT
CONFERENCE AND ORDER

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Plaintiff,
v.

15 BANK OF AMERICA CORPORATION,
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(N.D. Local Rules 6-1(b), 6-2(a))

Defendant.

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WHEREAS, pursuant to the Court's order of July 9, 2012, Defendant Bank of America

19 Corporation ("Defendant") and Plaintiff Omid Behjou ("Plaintiff") (collectively, the "Parties") are
20 calendared to appear for an Initial Case Management Conference ("CMC") on August 24, 2012
21 (Dkt. 19);
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WHERAS, Plaintiff Omid Behjou brought an action against Defendant and other parties,

23 Behjou v. Bank of America Group Benefits, et al, United States District Court, Northern District of
24 California, Case No. CV-10-3982-JBA (JCS) ("Behjou 1"). On June 25, 2012, the parties to
25 Behjou 1 participated in a settlement conference with Magistrate Judge Joseph C. Spero and
26 resolved the case;
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4457296.1

WHEREAS, the Parties participated in a settlement conference with Judge Spero on July

28 19, 2012 in the above-captioned action. The Parties agreed that they would engage in limited
CV 12 1590 CRB
-1SECOND JOINT STIPULATION TO EXTEND CASE MANAGEMENT CONFERENCE AND [PROPOSED]
ORDER

1 discovery to further the possibility of settlement. A further settlement conference was ordered by
2 Judge Spero for November 1, 2012 (Dkt. 20);
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WHEREAS, for the reasons of judicial economy, there is good cause to extend the Case

4 Management Conference date by 98 days from August 24, 2012 to November 30, 2012 as set forth
5 in the attached declaration of Raymond F. Lynch;
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WHEREAS, this is the second request for extension of the Case Management Conference;

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NOW THEREFORE, the Parties, by and through their respective counsel of record, hereby

8 stipulate and agree as follows, and respectfully ask the Court to sign this stipulation as its Order:
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The Case Management Conference is rescheduled for 8:30 a.m. on December 7, 2012, and

10 all associated deadlines shall be in accordance with FRCP 26(f) and (d), ADR Local Rule 3-5,
11 Civil L.R. 16 and the Court's Standing Orders.
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This stipulation is presented pursuant to Local Rules 6-1(b) and 6-2(a).
IT IS SO STIPULATED between the parties.

14 DATED: August 2, 2012

HANSON BRIDGETT LLP

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By:
/s/ Jane M. Feddes
RAYMOND F. LYNCH
SARAH D. MOTT
JANE M. FEDDES
Attorneys for Defendant
BANK OF AMERICA

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4457296.1

CV 12 1590 CRB
-2SECOND JOINT STIPULATION TO EXTEND CASE MANAGEMENT CONFERENCE AND [PROPOSED]
ORDER

1 DATED: August 2, 2012

LAW OFFICES OF RICHARD M. ROGERS
LAW OFFICES OF LAURENCE R. PADWAY

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By:

/s/ Richard M. Rogers
RICHARD M. ROGERS
LAURENCE F. PADWAY
Attorneys for Plaintiff
OMID BEHJOU

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4457296.1

CV 12 1590 CRB
-3SECOND JOINT STIPULATION TO EXTEND CASE MANAGEMENT CONFERENCE AND [PROPOSED]
ORDER

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2 PURSUANT TO THE FOREGOING STIPULATION, IT IS SO ORDERED.
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HON. CHARLES R. BREYER
United States Judge

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4 Dated: August 6, 2012

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4457296.1

CV 12 1590 CRB
-4SECOND JOINT STIPULATION TO EXTEND CASE MANAGEMENT CONFERENCE AND [PROPOSED]
ORDER