Anderegg v. American Express Centurion Bank

Filing 7

ORDER GRANTIGN STIPULATION 6 . Initial Case Management Conference set for 3/27/2013 03:00 PM in Courtroom A, 15th Floor, San Francisco. Joint Case Management Statement due by 3/20/2013. Signed by Judge Nathanael Cousins on 2/13/13. (lmh, COURT STAFF) (Filed on 2/13/2013)

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STROOCK & STROOCK & LAVAN LLP
JULIA B. STRICKLAND (State Bar No. 83013)
LISA M. SIMONETTI (State Bar No. 165996)
KRISTINA A. DEL VECCHIO (State Bar No. 283782)
2029 Century Park East
Los Angeles, CA 90067-3086
Telephone: [phone]
Facsimile: 310-556-5959
Email: [e-mail]

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Attorneys for Defendant
AMERICAN EXPRESS CENTURION BANK

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MICHAEL ANDEREGG,

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Plaintiff,
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vs.
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AMERICAN EXPRESS CENTURION BANK; )
AND DOES 1-20 INCLUSIVE,
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Defendants.
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Case No. 3:12-cv-06078-NC
[Assigned to the Hon. Nathanael Cousins]

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STIPULATION AND [PROPOSED]
ORDER TO CONTINUE THE INITIAL
CASE MANAGEMENT CONFERENCE
Action Filed: October 17, 2012
[Local Rule 6-1(b)]
[Declaration of Lisa M. Simonetti filed
concurrently]

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STIPULATION CONTINUING INITIAL CASE MANAGEMENT CONFERENCE
Case No. 3:12-cv-06078-NC

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WHEREAS, plaintiff Michael Anderegg (“Plaintiff”) filed his Complaint for Damages on
October 17, 2012 in the Superior Court for the County of Alameda;

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WHEREAS, on November 30, 2012, defendant American Express Centurion Bank

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(“Defendant”) removed the action to the United States District Court for the Northern District of

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California;

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WHEREAS, Defendant filed its answer to Plaintiff’s Complaint on December 17, 2012;

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WHEREAS, the Court has set the initial Case Management Conference for March 6, 2013

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at 3:00 p.m. (Dkt. No. 2);

2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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WHEREAS, due to a conflict of counsel on March 6, 2013, the parties have agreed to
continue the initial Case Management Conference to March 27, 2013;

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WHEREAS, pursuant to the Court’s Order Setting the initial Case Management Conference

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and ADR deadlines, if the Case Management Conference is continued, the other deadlines are

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continued accordingly;

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WHEREAS, pursuant to Civil Local Rules 6-1(b) and 6-2, the parties may request an order

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changing a deadline that would extend deadlines set forth in the Local Rules or Federal Rules; and

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WHEREAS, this Stipulation is made in good faith and not for purposes of delay.

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[Stipulation Continued On Next Page]

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-1STIPULATION CONTINUING INITIAL CASE MANAGEMENT CONFERENCE
Case No. 3:12-cv-06078-NC

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IT IS HEREBY STIPULATED by and between the parties, through their respective counsel
of record, as follows:
(a)

The date of the initial Case Management conference is continued from March 6,

2013 at 3:00 p.m. to March 27, 2013 at 3:00 p.m.;
(b)

The other deadlines set forth in the Court’s Order Setting the initial Case

to meet and confer regarding initial disclosures, early settlement, ADR process selection and

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discovery plan, to file ADR Certification and to file either a Stipulation to ADR Process or Notice

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2029 Century Park East
Los Angeles, California 90067-3086

Management Conference and ADR deadlines are continued accordingly as follows: (i) the last day

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STROOCK & STROOCK & LAVAN LLP

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of Need for ADR Phone Conference is continued to March 6, 2013; and (ii) the last day to file a

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Rule 26(f) report, complete initial disclosures or state objection in Rule 26(f) Report and file Case

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Management Statement is continued to March 20, 2013.

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IT IS SO STIPULATED.

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Dated: February 12, 2013

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STROOCK & STROOCK & LAVAN LLP
JULIA B. STRICKLAND
LISA M. SIMONETTI
KRISTINA A. DEL VECCHIO

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By:

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/s/ Lisa M. Simonetti
Lisa M. Simonetti

Attorneys for Defendant
AMERICAN EXPRESS CENTURION
BANK

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Dated: February 12, 2013
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KAZEROUNI LAW GROUP, APC
ABBAS KAZEROUNIAN

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By:

/s/ Abbas Kazerounian
Abbas Kazerounian

Attorneys for Plaintiff
MICHAEL ANDEREGG
-2STIPULATION CONTINUING INITIAL CASE MANAGEMENT CONFERENCE
Case No. 3:12-cv-06078-NC

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[PROPOSED] ORDER

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PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

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VED
APPRO

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LI
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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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Cousins

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NO

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.
thanael M
Judge Na

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The Honorable Nathanael S. Cousins

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UNIT
ED

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February 13, 2013
Dated: ________________________

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-3STIPULATION CONTINUING INITIAL CASE MANAGEMENT CONFERENCE
Case No. 3:12-cv-06078-NC

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CERTIFICATION OF SERVICE
I hereby certify that, on February 12, 2013, copies of the foregoing STIPULATION AND

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[PROPOSED] ORDER TO CONTINUE THE INITIAL CASE MANAGEMENT

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CONFERENCE were filed electronically and served by U.S. Mail on anyone unable to accept

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electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the court’s

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electronic filing system or by facsimile to anyone unable to accept electronic filing as indicated on

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the Notice of Electronic Filing. Parties may access this filing through the court’s EM/ECF System.

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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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By:

/s/ Lisa M. Simonetti
Lisa M. Simonetti

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-4STIPULATION CONTINUING INITIAL CASE MANAGEMENT CONFERENCE
Case No. 3:12-cv-06078-NC