Green v. Central Mortgage Company

Filing 97

STIPULATION AND ORDER Continuing Case Management Conference. Case Management Statement due by 3/16/2017. Further Case Management Conference set for 3/23/2017 11:00 AM in Courtroom C, 15th Floor, San Francisco. Signed by Judge Laurel Beeler on 02/16/2017. (tmiS, COURT STAFF) (Filed on 2/16/2017)

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NELSON W. GOODELL, ESQ., SBN 264734
The Goodell Law Firm
5 Third Street, Suite 1100
San Francisco, CA 94103
Tel. No. [phone]
Fax No. [phone]
Email: [e-mail]

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Attorney for Plaintiffs
ANGELIA GREEN and
THE ROBERT J. TREGRE JR. & ROSA L. TREGRE
FAMILY REVOCABLE LIVING TRUST

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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CASE NO.: C 14-04281 LB

ANGELIA GREEN, IN HER
INDIVIDUAL CAPACITY AND AS
TRUSTEE OF THE ROBERT J. TREGRE
JR. & ROSA L. TREGRE FAMILY
REVOCABLE LIVING TRUST; and THE
ROBERT J. TREGRE JR. & ROSA L.
TREGRE FAMILY REVOCABLE
LIVING TRUST, a California trust,
Plaintiffs,

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STIPULATION AND [PROPOSED]
ORDER FOR AN ORDER CONTINUING
THE CASE MANAGEMENT
CONFERENCE SCHEDULED FOR
FEBRUARY 23, 2017 AND PROVIDING
UPDATE ON STATUS OF DISMISSAL OF
CASE

v.
CENTRAL MORTGAGE COMPANY,
doing business in California as CENTRAL
MORTGAGE LOAN SERVICING
COMPANY; PLM LOAN
MANAGEMENT SERVICES, INC;
DEUTSCHE BANK NATIONAL TRUST
COMPANY AS TRUSTEE FOR
HARBORVIEW MORTGAGE LOAN
TRUST 2007-2, and Does 1 through 20,
inclusive,
Defendants.

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STIPULATION TO STAY CASE AND VACATE TRIAL AND RELATED DEADLINES

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TO THE CLERK OF THE COURT AND THE HONORABLE MAGISTRATE
JUDGE LAUREL BEELER:

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Having met and conferred, Plaintiffs ANGELIA GREEN and THE ROBERT J. TREGRE
JR. & ROSA L. TREGRE FAMILY REVOCABLE LIVING TRUST (the “Plaintiff”) and
Defendants

DEUTSCHE

BANK

NATIONAL

TRUST

COMPANY

and

CENTRAL

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MORTGAGE COMPANY (“Defendants”) enter into the below stipulation and hereby request

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that the Court enter the accompanying proposed order.

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Plaintiffs and Defendants, by and through their respective counsel, jointly stipulate as
follows:

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WHEREAS, on October 24, 2016 the Parties attended a mediation where they reached a

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tentative, conditional settlement agreement that would resolve this case in full;
WHEREAS, the Parties subsequently stipulated to stay this action and vacate the trial

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date;

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WHEREAS, the Court subsequently set a Case Management Conference for February 23,

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2017 and ordered the Parties to either file a voluntary dismissal or a joint statement discussing

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next steps by February 16, 2017;

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WHEREAS, the Parties are near completion of the conditions referenced in the settlement

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agreement entered into between them, but still need a little more time before a dismissal can be
filed;
NOW IT IS HEREBY STIPULATED AND AGREED by and between Defendants and
Plaintiffs, through their undersigned counsel of record that:

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1. The case will remain stayed.
2. The Parties wish to set a Case Management Conference for March 23, 2017 at 11:00 a.m.

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STIPULATION TO STAY CASE AND VACATE TRIAL AND RELATED DEADLINES

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3. In the event the case is not dismissed, a new trial date and all trial-related deadlines will

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be set at the March 23, 2017 Case Management Conference.

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Pursuant to Civil Local Rule 6-2, this is fifth request in this case to modify time deadlines

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in this case. The parties do not think that this modification would have any meaningful impact on

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the schedule for this case.

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IT IS SO STIPULATED.

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Dated: February 16, 2017

___/s/ Nelson W. Goodell___
NELSON W. GOODELL,
Attorney for Plaintiffs

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Approved as to form and content:

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Dated: February 16, 2017

____/s/ Joshua Hernandez__
JOSHUA HERNANDEZ,
Attorney for Defendants

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STIPULATION TO STAY CASE AND VACATE TRIAL AND RELATED DEADLINES

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CERTIFICATION

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Pursuant to Civil Local Rule 5-1(i)(3), I attest that I have obtained concurrence from

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Defendants’ counsel for the filing of this document.

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Dated: February 16, 2017

_/s/ Nelson W. Goodell____
NELSON W. GOODELL,
Attorney for Plaintiffs

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STIPULATION TO STAY CASE AND VACATE TRIAL AND RELATED DEADLINES

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ORDER

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The case remains stayed. A Case Management Conference will be set for March 23,

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2017. In the event that the case is not dismissed prior to that time, a new trial date and trial-

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related deadlines will be set at the March 23, 2017 Case Management Conference. An updated
Joint Case Management Statement will be due on March 16, 2017.

IT IS SO ORDERED.

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Dated: 02/16/2017

______________________________
Magistrate Judge Laurel Beeler

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STIPULATION TO STAY CASE AND VACATE TRIAL AND RELATED DEADLINES