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

Filing 22

ORDER granting 21 STIPULATION WITH PROPOSED ORDER to Continue Response Deadline and CMC filed by Neighborhood Assistance Corporation of America. Case Management Statement due by 10/4/2013. Initial Case Management Conference reset for 10/11/2013 08:30 AM in Courtroom 6, 17th Floor, San Francisco. Signed by Judge Charles R. Breyer on 8/27/2013. (beS, COURT STAFF) (Filed on 8/27/2013)

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KASOWITZ, BENSON, TORRES & FRIEDMAN LLP
Christopher J. McNamara (SBN 209205)
[e-mail]
Margaret A. Ziemianek (SBN 233418)
[e-mail]
101 California Street, Suite 2300
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff
Neighborhood Assistance Corporation of America

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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101 CALIFORNIA STREET, SUITE 2300
SAN FRANCISCO, CALIFORNIA 94111

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP

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SAN FRANCISCO DIVISION

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NEIGHBORHOOD ASSISTANCE
CORPORATION OF AMERICA, a Massachusetts
corporation,

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Plaintiff,
v.
NATIONAL MEDIA CONNECTION, LLC, a
Connecticut limited liability company, THE
NATIONAL MORTGAGE HELP CENTER,
LLC, a Connecticut limited liability company, and
MATTHEW S. GOLDREICH, an individual,

Case No. CV-13-1698-CRB
STIPULATION TO CONTINUE
RESPONSE DEADLINE AND CASE
MANAGEMENT CONFERENCE AND
ORDER
Hon. Charles R. Breyer
Complaint filed: April 15, 2013

Defendants.

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

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National Media Connection LLC, The National Mortgage Help Center LLC and Matthew S.

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Goldreich (“Defendants”) hereby stipulate and agree as follows:

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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 was served

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with the Summons and Complaint and that such service was deemed to have occurred on May 1,
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Stipulation; Case No. CV-13-1698-CRB

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2013;
WHEREAS the parties previously agreed that Defendants’ response to the Complaint
would be due on August 15, 2013; and
WHEREAS the parties are now engaged in settlement discussions which may result in a

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complete resolution of this entire litigation, and now wish to avoid the time and expense of

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litigating this action while such settlement discussions are ongoing;

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101 CALIFORNIA STREET, SUITE 2300
SAN FRANCISCO, CALIFORNIA 94111

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP

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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, by and between
the parties hereto and their respective undersigned attorneys, as follows:
1. The last day for Defendants to file a responsive pleading to the Complaint is extended to
September 6, 2013;
2. By entering into this Stipulation Defendants do not waive any challenges they may wish to

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make to the jurisdiction and/or venue of this Court, should this matter not settle; and

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3. The Case Management Conference presently scheduled for August 30, 2013 at 8:30 a.m.

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will be continued until October 11, 2013 at 8:30 a.m., and all deadlines tied to the Case

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Management Conference date shall be keyed to the new date.

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DATED: August 23, 2013

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP

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By:

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/S/ Christopher J. McNamara
Christopher J. McNamara

Attorneys for Plaintiff
Neighborhood Assistance Corporation of America

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DATED: August 23, 2013

FOX ROTHSCHILD LLP

By:

/S/ 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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Stipulation; Case No. CV-13-1698-CRB

PURSUANT TO STIPULATION, IT IS SO ORDERED.

________________________________________
United States District Court Judge
reyer
les R. B
ge Char
Jud

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101 CALIFORNIA STREET, SUITE 2300
SAN FRANCISCO, CALIFORNIA 94111

KASOWITZ, BENSON, TORRES & FRIEDMAN LLP

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August 27, 2013

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Stipulation; Case No. CV-13-1698-CRB

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