Neighborhood Assistance Corporation of America v. National Media Connection, LLC et al

Filing 14

ORDER granting 13 STIPULATION re Reponse Deadline filed by Matthew S. Goldreich, et al. Responsive pleading extended from 5/28/2013 to 6/18/2013. Signed by Judge Charles R. Breyer on 5/29/2013. (beS, COURT STAFF) (Filed on 5/30/2013)

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James E. Doroshow (SBN 112920)
[e-mail]
FOX ROTHSCHILD LLP
1800 Century Park East, Suite 300
Los Angeles, CA 90067-1506
Telephone: [phone]
Facsimile: 310-556-9828
Attorneys for Defendants,
NATIONAL MEDIA CONNECTION, LLC, NATIONAL
MORTGAGE HELP CENTER, LLC, AND MATTHEW
S. GOLDREICH

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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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NEIGHBORHOOD ASSISTANCE
12 CORPORATION OF AMERICA, a
Massachusetts corporation,
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Plaintiff,
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v.
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NATIONAL MEDIA CONNECTION,
16 LLC, a Connecticut limited liability
company, THE NATIONAL
17 MORTGAGE HELP CENTER, LLC, a
Connecticut limited liability company, and
18 MATTHEW S. GOLDREICH, an
individual,
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Defendants.
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Case No.: CV-13-01698-CRB
Hon. Judge Charles R. Breyer
STIPULATION RE RESPONSE
DEADLINE AND ORDER

Date Complaint Filed: 4/15/13

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20752686 05/30/2013

STIPULATION
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Plaintiff Neighborhood Assistance Corporation of America (“Plaintiff”) and

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Defendants National Media Connection, LLC, National Mortgage Help Center, LLC,

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and Matthew S. Goldreich (“Defendants”) hereby stipulate and agree as follows:
STIPULATION

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WHEREAS Plaintiff filed its Complaint against Defendants on April 15, 2013;

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WHEREAS the parties previously stipulated and agreed that each Defendant

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was served with the Summons and Complaint and that such service was deemed to

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have occurred on May 1, 2013;

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WHEREAS the parties previously agreed that Defendants’ response to the

10 Complaint would be due on May 28, 2013; and
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WHEREAS the parties are now engaged in settlement discussions which may

12 result in a complete resolution of this entire litigation, and now wish to avoid the time
13 and expense of litigating this action while such settlement discussions are ongoing;
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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and

15 between the parties hereto and their respective undersigned attorneys as follows:
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The last day for Defendants to file a responsive pleading to the

17 Complaint is extended from May 28, 2013 to June 18, 2013; and
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2.

By entering into this Stipulation Defendants do not waive any challenges

19 they may wish to make to the jurisdiction and/or venue of this Court, should this
20 matter not settle.
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Dated: May 24, 2013

FOX ROTHSCHILD LLP

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By: /James E. Doroshow/
James E. Doroshow
Attorneys for Defendants,
NATIONAL MEDIA CONNECTION, LLC,
NATIONAL MORTGAGE HELP CENTER, LLC,
AND MATTHEW S. GOLDREICH

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20752686 05/30/2013

STIPULATION
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Dated: May 24, 2013

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP

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By: /Christopher J. McNamara/
Christopher J. McNamara
Attorneys for Plaintiff,
NEIGHBORHOOD ASSISTANCE
CORPORATION OF AMERICA

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SO ORDERED:

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20752686 05/30/2013

R NIA

. Breyer

arles R
udge Ch

NO

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FO

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UNITED STATESRED
RDE DISTRICT COURT
JUDGE SO O
IS
IT

LI

Dated: May 29, 2013

UNIT
ED

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STIPULATION
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