Verhoek v. U.S. Bank National Association et al

Filing 44

STIPULATION AND ORDER re 43 Notice (Other), filed by U.S. Bank National Association, Set/Reset Deadlines as to 43 Notice (Other), 35 MOTION to Dismiss First Anded Complaint. Responses due by 8/13/2015. Replies due by 8/20/2 015. Motion Hearing set for 9/3/2015 01:30 PM in Courtroom 5, 17th Floor, San Francisco before Edward M. Chen. Case Management Statement due by 9/24/2015. Case Management Conference set for 10/1/2015 09:30 AM in Courtroom 5, 17th Floor, San Francisco.. Signed by Judge Edward M. Chen on 6/15/15. (bpf, COURT STAFF) (Filed on 6/15/2015)

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E. Scott Palmer, Esq., SBN 155376
Email: [e-mail]
Frederick A. Haist, Esq., SBN 211322
Email: [e-mail]
PALMER, LOMBARDI & DONOHUE LLP
515 South Flower Street, Suite 2100
Los Angeles, California 90071
Phone: [phone]
Fax: [phone]
Attorneys for Defendant US Bank N.A. (also erroneously sued as U.S. Bank Home
Mortgage)

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

PALMER, LOMBARDI & DONOHUE LLP
515 South Flower Street, Suite 2100
Los Angeles, California 90071

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CHRISTINA VERHOEK, an
individual,

)
)
)
Plaintiff,
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vs.
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U.S. BANK NATIONAL
)
ASSOCIATION, a business entity of )
unknown form; U.S. BANK HOME )
MORTGAGE, a business entity of
)
unknown form; and DOES 1-50,
)
)
Defendants.
)
)
)
)

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Case No. 14-cv-04821-EMC
[Assigned to the Honorable Edward M.
Chen]
NOTICE OF TENTATIVE
SETTLEMENT AND REQUEST AND
STIPULATION TO CONTINUE
DATES ON DEFENDANT US BANK
N.A.’S MOTION TO DISMISS
PLAINTIFF’S FIRST AMENDED
COMPLAINT AND TO CONTINUE
THE CASE MANAGEMENT
CONFERENCE

[filed: September 30, 2014]

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TO THE UNITED STATES DISTRICT COURT FOR THE NORTHERN

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DISTRICT OF CALIFORNIA, ALL PARTIES AND THEIR ATTORNEYS OF

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RECORD:

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Defendant US Bank N.A. (also erroneously sued as U.S. Bank Home

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Mortgage) (“US Bank”), and Plaintiff Christina Verhoek (“Verhoek”) have reached

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a tentative settlement of this case. The settlement has been reduced to writing but

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the Parties are still reviewing the settlement documents and determining if any

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revisions are necessary. [Haist Decl. ¶3.] The Parties believe that this case will be
-1NOTICE OF TENTATIVE SETTLEMENT AND REQUEST AND STIPULATION
TO CONTINUE DATES

14-cv-04821-EMC

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settled and the case dismissed with the next 30-60 days, and do not want to waste

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the parties and Court’s time with completing briefing on the pending motion to

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dismiss and conducting the case management conference if the case is settled.
Verhoek filed a First Amended Complaint on March 5, 2015. After obtaining

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an extension, US Bank filed a motion to dismiss the First Amended Complaint on

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April 27, 2015. The motion to dismiss hearing is set for July 2, 2015. Currently,

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Verhoek’s opposition is due on June 11, 2015, and US Bank’s reply is due on June

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18, 2015. The case management conference is set on August 8, 2015.
With the Court’s permission and order, US Bank and Verhoek hereby

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PALMER, LOMBARDI & DONOHUE LLP
515 South Flower Street, Suite 2100
Los Angeles, California 90071

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stipulate to extend the time for the parties to file further briefing on the April 27,

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2015 filed motion to dismiss. The parties propose and agree that the motion hearing

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date be continued to September 3, 2015, at 1:30 p.m. Verhoek’s opposition shall be

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due 21 days before the September 3, 2015 hearing date (i.e., August 13, 2015), and

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US Bank’s reply shall be due 14 days before the September 3, 2015 hearing (i.e.,

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August 20, 2015). The August 6, 2015 case management conference shall be

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continued to October 1, 2015 at 9:30 a.m.

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DATED: June 9, 2015

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By

/s/ Frederick A. Haist
E. SCOTT PALMER
FREDERICK A. HAIST
PALMER, LOMBARDI & DONOHUE LLP
Attorneys for US Bank N.A.

By

/s/ Nathan L. Scheg
NATHAN L. SCHEG
IRONHORSE LAW GROUP, PC
Attorneys for Christina Verhoek

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DATED: June 9, 2015

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///
-2NOTICE OF TENTATIVE SETTLEMENT AND REQUEST AND STIPULATION
TO CONTINUE DATES

14-cv-04821-EMC

PURSUANT TO STIPULATION, IT IS SO ORDERED.

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S

_________________________________
D
United States District CourtEJudge
ORDER
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6/15
DATED: ____________, 2015

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PALMER, LOMBARDI & DONOHUE LLP
515 South Flower Street, Suite 2100
Los Angeles, California 90071

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-3NOTICE OF TENTATIVE SETTLEMENT AND REQUEST AND STIPULATION
TO CONTINUE DATES

14-cv-04821-EMC