Hartford Fire Insurance Company v. Bank of America, N.A. et al
STIPULATION AND ORDER re 23 STIPULATION WITH PROPOSED ORDER re 22 Order Dismissing Case Joint Stipulation Requesting Extension of Automatic Dismissal Deadline in Court's November 14, 2012 Order filed by Hartford Fire Insurance Company, LoanCity, Richard D. Soukoulis, Blue Ridge Investments, L.L.C., Bank of America, N.A.. Signed by Judge ARMSTRONG on 12/11/12. (lrc, COURT STAFF) (Filed on 12/13/2012)
Case4:12-cv-02460-SBA Document23 Filed12/11/12 Page1 of 3
1 MARK JOSEPH KENNEY (State Bar No. 87345)
2 JAN T. CHILTON (State Bar No. 47582)
3 CHARLES D. MARSHALL (State Bar No. 236444)
4 SEVERSON & WERSON
A Professional Corporation
5 One Embarcadero Center, Suite 2600
San Francisco, California 94111
6 Telephone: (415) 398-3344
Facsimile: (415) 956-0439
Attorneys for Defendants, Counterclaimants and
8 Third Party Plaintiffs Bank of America, N.A. and
Blue Ridge Investments, L.L.C.
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA — OAKLAND DIVISION
13 HARTFORD FIRE INSURANCE
BANK OF AMERICA, N.A., et al.,
Case No. CV 12-2460-SBA
JOINT STIPULATION REQUESTING
EXTENSION OF AUTOMATIC
DISMISSAL DEADLINE IN COURT’S
NOVEMBER 14, 2012 ORDER
1 - 4th Floor
The Hon. Saundra Brown Armstrong
19 AND RELATED COUNTERCLAIMS AND
THIRD PARTY COMPLAINTS
Case4:12-cv-02460-SBA Document23 Filed12/11/12 Page2 of 3
This Stipulation is entered into by and between Plaintiff Hartford Fire Insurance Company,
2 Bank of America, N.A., Blue Ridge Investments, L.L.C., Loancity, and Richard D. Soukoulis,
3 through their counsel of record. This Stipulation is made in consideration of the following facts
4 and circumstances.
Plaintiff filed its complaint for declaratory action on May 15, 2012. [Dkt. No. 1].
On September 13, 2012, this Court entered an order granting the parties’ stipulated
7 request for referral to Magistrate Judge Donna M. Ryu for an early settlement conference. [Dkt
8 No. 19].
On November 9, 2012, the parties conducted an early settlement conference in front
10 of Magistrate Judge Ryu. The conference was a success, and the parties agreed to fully settle the
11 matter with settlement documents to be finalized in the weeks after the conference. [Dkt. No. 21].
On November 14, 2012, this Court entered an order conditionally dismissing the
13 matter with prejudice, with the order set to become final within 30 days of the entry of the order,
14 or December 14, 2012. [Dkt. No. 22].
The parties have made a good faith effort to finalize the settlement documents
16 within the period set forth in the November 14, 2012, order but given the intervening holiday and
17 schedules of counsel and the parties, the parties require an extension of time to finalize the
IT IS NOW THEREFORE STIPULATED AND AGREED by and between the parties
21 hereto and through their respective counsel that the date on which the November 14, 2012,
22 conditional order of dismissal [Dkt. No. 22] becomes final be extended by 31 days—or until
23 January 14, 2012, to allow for the finalization of the settlement documents.
Case4:12-cv-02460-SBA Document23 Filed12/11/12 Page3 of 3
1 DATED: December 10, 2012
/s/ Charles D. Marshall
Charles D. Marshall
Attorneys for Defendants BANK OF AMERICA, N.A.
and BLUE RIDGE INVESTMENTS, L.L.C.
DATED: December 10, 2012
/s/ James D. Curran
James D. Curran
Attorneys for Plaintiff HARTFORD FIRE
13 DATED: December 10, 2012
/s/ David Sturgeon-Garcia
David Sturgeon Garcia
Attorneys for Defendants LOANCITY and RICHARD
I, Charles D. Marshall, am the ECF user whose identification and password are being used
to file this Joint Stipulation. I hereby attest that James D. Curran and David Sturgeon-Garcia have
concurred in this filing.
By: _____/s/ Charles D. Marshall____
IT IS SO ORDERED.
This ________ day of ________ 2012.
The Honorable Saundra Brown Armstrong
United States District Judge
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