Pham v. Redline Recovery Services, LLC et al
Filing
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STIPULATION AND ORDER re 30 as to Fact Discovery Cutoff. Fact Discovery Cutoff is 4/1/2014. Signed by Judge Howard R. Lloyd on 2/25/2014. (hrllc1, COURT STAFF) (Filed on 2/25/2014)
*E-Filed: February 25, 2014*
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PHILIP A. MCLEOD, CASB No. 101101
philip.mcleod@kyl.com
JESSICA LUHRS, CASB No. 284846
jessica.luhrs@kyl.com
KEESAL, YOUNG & LOGAN
A Professional Corporation
450 Pacific Avenue
San Francisco, California 94133
Telephone:
(415) 398-6000
Facsimile:
(415) 981-0136
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Attorneys for Defendant JPMORGAN CHASE BANK, N.A., successor by merger to
CHASE HOME FINANCE, LLC
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA
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HOAN PHAM,
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Plaintiff,
vs.
REDLINE RECOVERY SERVICES, LLC;
JP MORGAN CHASE BANK, N.A.; and
CHASE HOME FINANCE, LLC,
Defendants.
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Case No. CV 13-01843 HRL
STIPULATION TO MODIFY CASE
MANAGEMENT ORDER AS TO FACT
DISCOVERY CUTOFF; [PROPOSED]
ORDER
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Plaintiff HOAN PHAM (“Plaintiff”) and Defendants JPMORGAN CHASE BANK, N.A.,
successor by merger to CHASE HOME FINANCE, LLC (“Chase”) and REDLINE RECOVERY
SERVICES, LLC (“Redline”) (collectively, the “Parties”), by and through their respective counsel of
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record, hereby stipulate and agree as follows:
WHEREAS, on July 31, 2013, this court issued a Case Management Order providing for a fact
discovery cut-off date of January 28, 2014;
WHEREAS, the Parties stipulated to extend the fact discovery cut-off date to March 18, 2014,
and the Court issued an Order on that stipulation on January 13, 2014;
-1KYL_SF630399
STIPULATION TO MODIFY CASE MANAGEMENT ORDER AS TO FACT DISCOVERY
CUTOFF; [PROPOSED] ORDER - Case No. CV 13-01843 HRL
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WHEREAS, the Parties are currently engaged in settlement discussions, and wish to extend the
fact discovery cut-off date in order to continue to facilitate those discussions;
WHEREAS, the Parties are desirous of changing the fact discovery cut-off date to April 1,
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2014, with the deadline to respond to written discovery extended to March 17, 2014, and all
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depositions to be held no earlier than the week of March 17, 2014;
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WHEREAS, good cause exists to enter an order modifying the fact discovery cut-off date in
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that it will not affect any other date in the current Case Management Order, including the date of the
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Pretrial Conference;
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IT IS HEREBY STIPULATED by and between all Parties to this action through their
respective counsel that the fact discovery cut-off date should be reset to April 1, 2014, with the
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deadline to respond to written discovery extended to March 17, 2014, and all depositions to be held no
earlier than the week of March 17, 2014.
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DATED: February 24, 2014
/s/ Jessica Luhrs___________________
PHILIP A. MCLEOD
JESSICA LUHRS
KEESAL, YOUNG & LOGAN
Attorneys for Defendant JPMORGAN CHASE
BANK, N.A., successor by merger to
CHASE HOME FINANCE, LLC
DATED: February 24, 2014
/s/ James F. Hetherington___________________
JAMES F. HETHERINGTON
GOODMAN NEUMAN HAMILTON LLP
Attorney for Defendant REDLINE RECOVERY
SERVICES, LLC
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//
-2KYL_SF630399
STIPULATION TO MODIFY CASE MANAGEMENT ORDER AS TO FACT DISCOVERY
CUTOFF; [PROPOSED] ORDER - Case No. CV 13-01843 HRL
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DATED: February 24, 2014
/s/ Annette D. Kirkham___________________
ANNETTE D. KIRKHAM
FAIR HOUSING LAW PROJECT
LAW FOUNDATION OF SILICON VALLEY
Attorney for Plaintiff HOAN PHAM
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Filer’s Attestation: Pursuant to Civil Local Rule 5-1(i)(3) regarding signatures, Jessica Luhrs hereby
attests that concurrence in the filing of this document has been obtained.
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-3KYL_SF630399
STIPULATION TO MODIFY CASE MANAGEMENT ORDER AS TO FACT DISCOVERY
CUTOFF; [PROPOSED] ORDER - Case No. CV 13-01843 HRL
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[PROPOSED] ORDER
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PURSUANT TO THE STIPULATION OF THE PARTIES, IT IS HEREBY ORDERED
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THAT the Case Management Order issued July 31, 2013 should be and hereby is modified to reflect a
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Fact Discovery Cutoff date of April 1, 2014.
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IT IS SO ORDERED.
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Dated: February 25, 2014
__________________________________
Magistrate
The Honorable^Judge Howard R. Lloyd
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-4KYL_SF630399
STIPULATION TO MODIFY CASE MANAGEMENT ORDER AS TO FACT DISCOVERY
CUTOFF; [PROPOSED] ORDER - Case No. CV 13-01843 HRL
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