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

Filing 16

ORDER granting 15 STIPULATION WITH PROPOSED ORDER re 10 Stipulation, 14 Order, Terminate Motions, 11 Case Management Scheduling Order filed by Matthew S. Goldreich, National Media Connection, LLC, The National Mortgage Help Center, LLC. Case Management Statement due by 8/23/2013. Initial Case Management Conference reset for 8/30/2013 08:30 AM in Courtroom 6, 17th Floor, San Francisco. Signed by Judge Charles R. Breyer on 6/13/2013. (beS, COURT STAFF) (Filed on 6/18/2013)

Case3:13-cv-01698-CRB Document15 Filed06/12/13 Page1 of 3

1
2
3
4
5
6

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

7
8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10

SAN FRANCISCO DIVISION

11

NEIGHBORHOOD ASSISTANCE
12 CORPORATION OF AMERICA, a
Massachusetts corporation,
13
Plaintiff,
14
v.
15
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,
19
Defendants.
20

Case No.: CV-13-01698-CRB
Hon. Judge Charles R. Breyer
STIPULATION RE RESPONSE
DEADLINE AND CONTINUING
CASE MANAGEMENT
CONFERENCE AND RELATED
DEADLINES AND [PROPOSED]
ORDER

Date Complaint Filed: 4/15/13

21
22
23
24
25
26
27
28
STIPULATION
1

Case3:13-cv-01698-CRB Document15 Filed06/12/13 Page2 of 3

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

1
2

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

3

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

4
5

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

6

WHEREAS the parties previously stipulated and agreed that each Defendant

7

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

8

have occurred on May 1, 2013;

9

WHEREAS the parties previously agreed that Defendants’ response to the

10 Complaint would be due on June 18, 2013; and
11

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;
14

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and

15 between the parties hereto and their respective undersigned attorneys as follows:
16

1.

The last day for Defendants to file a responsive pleading to the

17 Complaint is extended from June 18, 2013 to July 5, 2013; and
18

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.
21

3.

The Case Management Conference presently scheduled before the Court

August 30
8:30
22 on July 19, 2013 at 8:30 a.m. will be continued until _____________, 2013 at ____

23 a.m., and all other deadlines set forth in the Court’s Order Setting Case Management
24 Conference dated April 8, 2013 are hereby vacated and shall be continued by thirty
25 (30) days.
26 ///
27 ///
28 ///
STIPULATION
2

Case3:13-cv-01698-CRB Document15 Filed06/12/13 Page3 of 3

1

Dated: June 12, 2013

FOX ROTHSCHILD LLP

2
By: /James E. Doroshow/
James E. Doroshow
Attorneys for Defendants,
NATIONAL MEDIA CONNECTION, LLC,
NATIONAL MORTGAGE HELP CENTER, LLC,
AND MATTHEW S. GOLDREICH

3
4
5
6
7

Dated: June 12, 2013

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP

8
9

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

10
11
SO ORDERED:

13

RT

19

yer

s R. Bre

harle
Judge C

ER

A

H

20

R NIA

IT I

NO

18

UNITED STATES DISTRICT COURT
ERED
JUDGE
O ORD
SS

FO

17

UNIT
ED

16

June 13 , 2013

RT
U
O

15 Dated:

S

14

S DISTRICT
TE
C
TA

LI

12

N

21
22
23
24
25
26
27
28
STIPULATION
3

F
D IS T IC T O
R

C