Zucchi et al v. Credit Protection Association, L.P.

Filing 19

ORDER EXTENDING Mediation deadline re 18 . Case Management Conference set for 3/20/2013 03:00 PM in Courtroom A, 15th Floor, San Francisco. Signed by Judge Nathanael Cousins on 1/3/13. (lmh, COURT STAFF) (Filed on 1/3/2013)

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Todd M. Friedman (216752)
Nicholas J. Bontrager (252114)
Law Offices of Todd M. Friedman, P.C.
369 S. Doheny Dr. #415
Beverly Hills, CA 90211
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorney for Plaintiff

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DAVID I. DALBY SBN:114750
HINSHAW & CULBERTSON
One California Street, 18th Floor
San Francisco, CA 94111
Telephone: [phone]
Facsimile: 415-834-9070
Attorneys for Defendant

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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

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CASE NO.: 3:12-CV-04109-NC
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MILO ZUCCHI AND DARLISA
ZUCCHI,
Plaintiffs,

JOINT STIPULATION TO
CONTINUE MEDIATION
COMPLETION DATE

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vs.
CREDIT PROTECTION
ASSOCIATION, L.P.,
Defendant.

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COMES NOW, Plaintiffs Milo Zuuchi and Darlisa Zucchi and Defendant
Credit Protection Assocation, L.P., by and through respective counsel, hereby

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stipulates as follows:
Stipulation to Continue Mediation Completion Date

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1. WHEREAS, this Court ordered the parties to mediation to be completed

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by January 14, 2013;
2. WHEREAS, on December 5, 2012, the parties, through counsel
conducted an initial telephone conference with the Court-Appointed

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mediator assigned to this matter;
3. WHEREAS, the Parties and mediator discussed the current stage of

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litigation and that both parties are currently engaging in written
discovery;

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4. WHEREAS, the Parties have received the approval of the Court13
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Appointed mediator to submit the instant stipulation requesting that the

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mediation completion date be extended in order for the parties to

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complete written discovery prior to conducting a mediation;
5. WHEREAS, there have been no previous requests for a continuance of

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the mediation completion date or the Further Case Management
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Conference date;
6. WHEREAS, the Parties agree that it would be prudent and promote

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judicial efficiency to continue the mediation completion date and

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Further Case Management Conference date for approximately sixty (60)

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days or to March 15, 2012;

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Stipulation to Continue Mediation Completion Date

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7. WHEREAS, no Parties will be prejudiced as a result of the requested

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continuances.
NOW THEREFORE, the Parties, through their respective counsel of
record, stipulate and agree to a continuance of a the Mediation Completion date to

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March 15, 2013, or any date thereafter that the Court deems proper.
SO STIPULATED.

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By: _s/Todd M. Friedman
Todd M. Friedman (216752)
Law Offices of Todd M. Friedman, P.C.
Attorney for Plaintiff

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By:_s/David I. Dalby
David I. Dalby
HINSHAW & CULBERTSON LLP
Attorney for Defendant

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Stipulation to Continue Mediation Completion Date

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Filed electronically on this 2nd day of January, 2013, with:

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United States District Court CM/ECF system
Notification sent electronically on this 2nd day of January, 2013, to:

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David I. Dalby
HINSHAW & CULBERTSON
Attorney for Defendant

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This 2nd day of January, 2013

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s/Todd Friedman
Todd Friedman

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Stipulation to Continue Mediation Completion Date

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UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF CALIFORNIA

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CASE NO.: 3:12-CV-04109-NC

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MILO ZUCCHI AND DARLISA
ZUCCHI,

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Plaintiffs,

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[PROPOSED] ORDER GRANTING
JOINT STIPULATION TO
CONTINUE MEDIATION
COMPLETION DATE

vs.
CREDIT PROTECTION
ASSOCIATION, L.P.,

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Defendant.
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IT IS HEREBY ORDERED that the parties’ Stipulation to Continue the
Mediation Completion Date and Further Case Management Conference is

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GRANTED. The Mediation Completion Date is now _________________, 2013
March 15

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and the Further Case Management Conference will be held on

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_______________________, 2013 at ________am/pm.
March 20
3:00

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Dated:___________
January 3, 2013

By:____________________________________
Hon. United States District Court Judge