Gonzales v. CitiMortgage, Inc.

Filing 55

STIPULATION AND ORDER re 54 STIPULATION WITH PROPOSED ORDER Stipulation for Order to Continue the Mediation Deadline; [Proposed] Order filed by CitiMortgage, Inc. Case Management Statement due by 10/15/2015. Further Case Management Conference set for 10/22/2015 10:30 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 5/18/15. (bpf, COURT STAFF) (Filed on 5/18/2015)

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Andrew A. Bao (SBN 247092)
[e-mail]
Meagan S. Tom (SBN 273489)
[e-mail]
WOLFE & WYMAN LLP
2175 N. California Blvd., Suite 645
Walnut Creek, California 94596-3502
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
CITIMORTGAGE, INC.

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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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ELIZABETH GONZALES, an individual,
Plaintiff,

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Case No.: 3:14-cv-04059 EMC
STIPULATION FOR ORDER TO
CONTINUE THE MEDIATION
DEADLINE; [PROPOSED] ORDER

v.
CITIMORTGAGE, INC., a business entity; and
DOES 1 through 50, inclusive,

Hon. Edward M. Chen
Action Filed: 09/05/14
Trial Date:
None set.

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Defendants.
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The parties hereby stipulate as follows and respectfully request that the Court enter the
proposed order set forth below.
WHEREAS, on March 27, 2015, the Court ordered the parties to complete a mediation no
later than July 31, 2015;
WHEREAS, the Parties have been engaged in informal settlement discussions throughout the
pendency of this action;
WHEREAS, the Parties believe that they may reach a resolution of the entire case without
formal mediation with Court-appointed mediator, Benjamin Riley;
WHEREAS, the Parties believe that additional time to reach and finalize any resolution of
the entire case without formal mediation may require additional time past the July 31, 2015

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STIPULATION FOR ORDER TO CONTINUE THE MEDIATION DEADLINE
2003287.1

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mediation completion deadline; and
WHEREAS, the Parties agree that a continuance will be a more productive use of the Parties’
time and resources.

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NOW, THEREFORE, the parties STIPULATE and agree that the current deadline to

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complete mediation shall be continued no less than 60 (sixty) days, to September 30, 2015, or a later

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date selected by the Court.

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DATED: May 13, 2015

WOLFE & WYMAN LLP

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By: : /s/ Meagan S. Tom SBN 273489
ANDREW A. BAO
MEAGAN S. TOM
Attorneys for Defendant
CITIMORTGAGE, INC.

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DATED: May 12, 2015

MELLEN LAW FIRM

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By: /s/ Jessica Galletta
MATTHEW MELLEN
JESSICA GALLETTA
Attorneys for Plaintiff
ELIZABETH GONZALES

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ORDER
IT IS HEREBY ORDERED THAT the stipulation by the parties herein is GRANTED and

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the mediation completion date be continued from July 31, 2015 until September 30, 2015 or a later

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date selected by the court. Further CMC reset from 8/20/15 to 10/22/15 at 10:30 a.m.
An updated joint CMC statement shall be filed by 10/15/15,

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UNIT
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_____________________________________
ES D
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HONORABLE EDWARD M. CHEN

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FO

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STIPULATION FOR ORDER TO CONTINUE THE MEDIATION DEADLINE
2003287.1

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PROOF OF SERVICE
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STATE OF CALIFORNIA

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COUNTY OF CONTRA COSTA

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I, Kimberly Ward, declare that I am employed in the County of Contra Costa, State of California. I am over
the age of 18 and not a party to the within action. My business address is 2175 N. California Blvd., Suite 645,
Walnut Creek, California 94596-3502.

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ss.

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On the date shown below, I served the document(s) described as STIPULATION FOR ORDER TO
CONTINUE THE MEDIATION DEADLINE; [PROPOSED] ORDER on all interested parties in said action by
placing a true copy thereof in a sealed envelope addressed as stated on the ATTACHED SERVICE LIST.

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BY MAIL: as follows:
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STATE - I am "readily familiar" with Wolfe & Wyman LLP' s practice of collection and
processing correspondence for mailing. Under that practice it would be deposited with the U.S. Postal
Service on that same day with postage thereon fully prepaid at Walnut Creek, California, in the
ordinary course of business. I am aware that on motion of party served, service is presumed invalid if
postal cancellation date or postage meter date is more than one (I) day after date of deposit for mailing
in affidavit.
FEDERAL - I deposited such envelope in the U.S. Mail at Walnut Creek, California, with
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postage thereon fully prepaid.

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BY PERSONAL SERVICE as follows: I caused a copy of such document(s) to be delivered by hand
to the offices of the addressee between the hours of9:00 A.M. and 5:00P.M.

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BY OVERNIGHT COURIER SERVICE as follows: I caused such envelope to be delivered by
overnight courier service to the offices of the addressee. The envelope was deposited in or with a
facility regularly maintained by the overnight courier service with delivery fees paid or provided for.

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BY ELECTRONIC MAIL as follows: I hereby certify that I electronically transmitted the attached
document(s) to the U.S. District Court using the CM/ECF System for filing, service and transmittal of
Notice of Electronic Filing to the CM/ECF registrants for this case. Upon completion of the electronic
transmission of said document(s), a receipt is issued to the serving party acknowledging receipt by
ECF's system, which will be maintained with the original document(s) in our office.

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BY FACSIMILE as follows: I caused such documents to be transmitted to the telephone number of
the addressee listed on the attached service list, by use of facsimile machine telephone number. The
facsimile machine used complied with California Rules of Court, Rule 2004 and no error was reported
by the machine. Pursuant to California Rules of Court, Rule 2006(d), a transmission record of the
transmission was printed.

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STATE
I declare under penalty of perjury under the laws of the State of California that the
above is true and correct.

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FEDERAL
I declare that I am employed in the offices of a member of the State Bar of this Court
at whose direction the service was made.

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Executed on May 13,2015, at Walnut Creek, California. (

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_________________

-K-UMB-4~E=RL--Y_W_A_RD

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1812003.1

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SERVICE LIST
Elizabeth Gonzales v. CitiMortgage, Inc., et al.
U.S. District Court, Northern District Case No. 3:14-cv-04059 EMC
W&W File No. 1133-1415
[Revised: 09/24/14)

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1812003.1

Matthew David Mellen, Esq.
Jessica Ryan Galletta, Esq.
MELLEN LAW FIRM
411 Borel Avenue, Suite 230
San Mateo, CA 94402

Attorneys for Plaintiff
ELIZABETH GONZALES
Tel.: [phone]
Fax: [phone]
Email: [e-mail]