Keen et al v. JPMorgan Chase Bank, N.A.

Filing 34

ORDER adopting 32 STIPULATION WITH PROPOSED ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE. Case Management Statement due by 11/3/2015. Case Management Conference set for 11/10/2015 02:00 PM in Courtroom 2, 17th Floor, San Francisco. Signed by Judge William H. Orrick on 07/22/2015. (jmdS, COURT STAFF) (Filed on 7/22/2015)

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MASSEY & GAIL LLP
LEONARD A. GAIL
(admitted pro hac vice)
[e-mail]
50 East Washington Street, Suite 400
Chicago, IL 60602
Tel: [phone]; Fax: [phone]
JONATHAN S. MASSEY
(admitted pro hac vice)
[e-mail]
1325 G St., N.W., Suite 500
Washington, D.C. 20005
Tel.: [phone]; Fax: [phone]

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PAMELA T. JOHANN (No. 145558)
[e-mail]
100 Pine Street, Suite 1250
San Francisco, CA 94111
Tel: [phone]; Fax: [phone]

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Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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KEVIN J. KEEN, an individual; TAMRA
E. KEEN, an individual; CURT
CONYERS, an individual; KELLY E.
CONYERS, an individual; on behalf of
themselves and all others similarly
situated,

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STIPULATED MOTION TO
CONTINUE CASE
MANAGEMENT CONFERENCE

Plaintiffs,

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No. 3:15-CV-1806-WHO

v.
JPMORGAN CHASE BANK, N.A.,
Defendant.

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STIPULATED MOTION TO CONTINUE CASE MANAGEMENT CONFERENCE

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Pursuant to Civil Local Rules 7-1(a)(5), 7-12, and 16-2, Defendant JPMorgan Chase

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Bank, N.A. (“Chase”) and Plaintiffs Kevin J. Keen et al., by and through their respective

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counsel, hereby stipulate as follows:

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1.

On July 2, 2015, this Court entered an order continuing the Case

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Management Conference in this matter to September 15, 2015. This order was entered after

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a stipulated motion to continue the Case Management Conference in light of a pending

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Motion to Dismiss, which was set for hearing on August 5, 2015

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2.

On July 14, 2015, Plaintiffs filed a First Amended Complaint.

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3.

The parties are concurrently submitting a stipulation and proposed order to

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extend the time for Chase to answer or otherwise respond to the First Amended Complaint

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to August 28, 2015.

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4.

Chase intends to file a Motion to Dismiss the First Amended Complaint,

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which will raise issues that are potentially dispositive of this matter, or, alternatively, that

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might limit or otherwise affect the legal and factual contours of this case. Counsel for Chase

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has conferred with counsel for Plaintiffs, and both parties agree that in the name of judicial

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efficiency and economy, it would be prudent to delay the Case Management Conference

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until after the motion is resolved.

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4.

This stipulated request would not require any change to the ADR process or

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schedule. The parties have met and conferred regarding ADR process selection and agree

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that the case would not benefit from ADR at this time. The parties have submitted their

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ADR Certifications and Notice of Need for ADR Phone Conference. No ADR Phone

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Conference has been scheduled, and the parties agree that any such ADR Phone Conference

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should be held after the Motion to Dismiss has been resolved in advance of the rescheduled

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Case Management Conference.

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STIPULATED MOTION TO CONTINUE CASE MANAGEMENT CONFERENCE

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Accordingly, the parties hereby stipulate and jointly move this Court to continue the

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Case Management Conference to November 10, 2015, or to such date as the Court deems

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convenient following the resolution of the Motion to Dismiss.

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Dated: July ____, 2015

William McGrane, Esq.

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____________________
Attorney for Plaintiffs

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Dated: July 20, 2015

Leonard A. Gail, Esq.

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/s/ Leonard A. Gail
Attorney for Defendant

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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July 22, 2015
Dated: _____________

___________________________
The Honorable William H. Orrick

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STIPULATED MOTION TO CONTINUE CASE MANAGEMENT CONFERENCE