Green v. Eastmont Oakland Associates, LLC. et al

Filing 21

STIPULATION AND ORDER re 20 Proposed Order, filed by Scanlankemperbard Companies, Cheryl Green, Bank of America, NA, Eastmont Oakland Associates, LLC.. Signed by Judge ARMSTRONG on 6/23/10. (lrc, COURT STAFF) (Filed on 6/23/2010)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LAW OFFICES OF PAUL L. REIN, Esq. (SBN 43053) CELIA MCGUINNESS, Esq. (SBN 159420) CATHERINE M. CABALO, Esq. (SBN 248198) LAW OFFICES OF PAUL L. REIN 200 Lakeside Drive, Suite A Oakland, CA 94612 Telephone: 510/832-5001 Facsimile: 510/832-4787 reinlawoffice@aol.com Attorneys for Plaintiff CHERYL GREEN IN THE UNITED STATES DISTRICT COURT IN AND FOR THE NORTHERN DISTRICT OF CALIFORNIA CHERYL GREEN, Plaintiff, v. EASTMONT OAKLAND ASSOCIATES, LLC; SCANLANKEMPERBARD COMPANIES; BANK OF AMERICA, NA; and DOES 1-40 inclusive, Defendants. / STIPULATION The parties to the above captioned litigation hereby stipulate by and through their undersigned counsel of record to the following: The Deadline to Complete Mediation in this matter, per General Order 56, is scheduled for June 30, 2010. The subject property is so large that the parties completed the site inspection in two stages. The first inspection took place on November 10, 2009, and the second inspection took place recently on February 8, 2010. Given the STIPULATION AND PROPOSED ORDER TO CONTINUE DEADLINE TO COMPLETE MEDIATION CASE C09-03682 SBA C:\Documents and Settings\Workstation\Local Settings\Temp\notes06E812\~5976268.wpd Case No. C09-03682 SBA Civil Rights STIPULATION AND ORDER TO CONTINUE DEADLINE TO COMPLETE MEDIATION PAUL L. REIN 200 LAKESIDE DR., SUITE A OAKLAND, CA 94612-3503 (510) 832-5001 1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LAW OFFICES OF large size of the subject premises, it has taken more time for plaintiff's expert to complete his report and Plaintiff has still not received it. Plaintif's expert has informed plaintiff's counsel that the report will be ready Monday, June 28, 2010. Thereafter, the parties intend to exchange information from their respective consultants in an effort to settle the case. Therefore, the parties hereby request that the Court continue the June 30, 2010 Deadline to Complete Mediation until September 30, 2010, so that the parties may continue the General Order 56 process and conduct a mediation. Good cause exists to request the continuance on the grounds that the parties are still actively negotiating settlement, continue to remain cooperative in the exchange of information, and believe that a continuance of the Deadline to Complete Mediation will conserve attorneys fees and court resources. IT IS SO STIPULATED. Dated: June 21, 2010 LAW OFFICES OF PAUL L. REIN /s/ Celia McGuinness By: Celia McGuinness, Esq. Attorneys for Plaintiff CHERYL GREEN Dated: June 21, 2010 SHEPPARD MULLIN /s/ Robert Stumpf By: Robert Stumpf, Esq. Attorneys for Defendants EASTMONT OAKLAND ASSOCIATES LLC and SCANLANKEMPERBARD COMPANIES // // STIPULATION AND PROPOSED ORDER TO CONTINUE DEADLINE TO COMPLETE MEDIATION CASE C09-03682 SBA C:\Documents and Settings\Workstation\Local Settings\Temp\notes06E812\~5976268.wpd PAUL L. REIN 200 LAKESIDE DR., SUITE A OAKLAND, CA 94612-3503 (510) 832-5001 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 LAW OFFICES OF Dated: June 21, 2010 BUCHALTER NENER /s/ William Miller, Esq. By: William Miller, Esq. Attorneys for Defendant BANK OF AMERICA, NA ORDER Pursuant to the Stipulation of the Parties it is hereby ordered that the Deadline to Complete Mediation in this matter be continued to _9/30/10. IT IS SO ORDERED. Dated: 6/23/10 SAUNDRA B. ARMSTRONG DISTRICT JUDGE PAUL L. REIN 200 LAKESIDE DR., SUITE A OAKLAND, CA 94612-3503 (510) 832-5001 STIPULATION AND PROPOSED ORDER TO CONTINUE DEADLINE TO COMPLETE MEDIATION CASE C09-03682 SBA C:\Documents and Settings\Workstation\Local Settings\Temp\notes06E812\~5976268.wpd 3

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