Friedrichs v. BMW Financial Services LLC

Filing 14

STIPULATION AND ORDER TO CONTINUE CASE MANAGEMENT CONFERENCE re 13 Stipulation filed by BMW Financial Services LLC, Derek Friedrichs. Signed by Judge Phyllis J. Hamilton on 12/17/08. (nah, COURT STAFF) (Filed on 12/17/2008)

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JEFFER, MANGELS, BUTLER & MARMARO LLP MICHAEL J. HASSEN (Bar No. 124823) CHRISTOPHER H. DOYLE (Bar No. 190016) Two Embarcadero Center, Fifth Floor San Francisco, California 94111-3824 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant BMW FINANCIAL SERVICES, LLC

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DEREK FRIEDRICHS, individually and on behalf of all others similarly situated, Plaintiff, v. BMW FINANCIAL SERVICES LLC, a limited liability company, and DOES 1-25, inclusive, Defendants. CASE NO. C 08-04486 PJH

STIPULATION TO EXTEND DEADLINES AND CONFERENCE DATES; [PROPOSED] ORDER

IT IS HEREBY STIPULATED AND AGREED by the between the plaintiff, DEREK FRIEDRICHS, by and through his attorney of record, and defendant BMW FINANCIAL SERVICES LLC, by and through its attorneys of record, as follows: WHEREAS, plaintiff and defendant are in the midst of settlement discussions and believe that those discussions will prove fruitful; WHEREAS, the Court has scheduled a Case Management Conference to be held in this case on January 8, 2009, at 2:30 p.m., in Courtroom 3 of the above-captioned court; WHEREAS, the parties desire to extend all statutory and court deadlines and hearings in this matter by 30 days so that they may focus their efforts on settlement negotiations; and
STIPULATION TO EXTEND DEADLINES

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WHEREAS, no prejudice shall result from a continuance of the deadlines and Case Management Conference dates. The parties hereby respectfully request that the Court reschedule the January 8, 2009, 5 Case Management Conference for February 9, 2009, and continue all statutory and court deadlines for a period of 30 days.

DATED: December 15, 2008

JEFFER, MANGELS, BUTLER & MARMARO LLP

By: _______________/s/________________________ MICHAEL J. HASSEN Attorneys for Defendant BMW FINANCIAL SERVICES, LLC DATED: December 15, 2008 CHAVEZ & GERTLER LLP

MARK A. CHAVEZ Attorneys for Plaintiff DEREK FRIEDRICHS Dated: December 15, 2008

By:

I certify that Michael J. Hassen has authorized me to sign this Stipulation on his behalf.

Mark A. Chavez

STIPULATION TO EXTEND DEADLINES

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ORDER

Based on the Stipulation of the parties, and good cause appearing: IT IS HEREBY ORDERED that all statutory and court deadlines in this matter are continued for 30 days; and IT IS HEREBY FURTHER ORDERED that the case management conference set for February 5, 2009 at 2:30 p.m. January 8, 2009, is rescheduled for ______________________.

12/17/08 DATED: ______________________

S DISTRICT TE C TA __________________________________

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Hon. Phyllis J. Hamilton United States District RDERED Court Judge

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