Pham v. Redline Recovery Services, LLC et al

Filing 31

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)

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*E-Filed: February 25, 2014* 1 2 3 4 5 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 6 7 Attorneys for Defendant JPMORGAN CHASE BANK, N.A., successor by merger to CHASE HOME FINANCE, LLC 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 11 HOAN PHAM, 12 13 14 15 16 Plaintiff, vs. REDLINE RECOVERY SERVICES, LLC; JP MORGAN CHASE BANK, N.A.; and CHASE HOME FINANCE, LLC, Defendants. ) ) ) ) ) ) ) ) ) ) ) Case No. CV 13-01843 HRL STIPULATION TO MODIFY CASE MANAGEMENT ORDER AS TO FACT DISCOVERY CUTOFF; [PROPOSED] ORDER 17 18 19 20 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 21 22 23 24 25 26 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 1 2 3 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, 4 2014, with the deadline to respond to written discovery extended to March 17, 2014, and all 5 6 depositions to be held no earlier than the week of March 17, 2014; 7 WHEREAS, good cause exists to enter an order modifying the fact discovery cut-off date in 8 that it will not affect any other date in the current Case Management Order, including the date of the 9 Pretrial Conference; 10 11 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 12 13 14 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. 15 16 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 17 18 19 20 21 22 23 24 25 26 // -2KYL_SF630399 STIPULATION TO MODIFY CASE MANAGEMENT ORDER AS TO FACT DISCOVERY CUTOFF; [PROPOSED] ORDER - Case No. CV 13-01843 HRL 1 2 3 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 4 5 6 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. 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 -3KYL_SF630399 STIPULATION TO MODIFY CASE MANAGEMENT ORDER AS TO FACT DISCOVERY CUTOFF; [PROPOSED] ORDER - Case No. CV 13-01843 HRL 1 [PROPOSED] ORDER 2 3 PURSUANT TO THE STIPULATION OF THE PARTIES, IT IS HEREBY ORDERED 4 THAT the Case Management Order issued July 31, 2013 should be and hereby is modified to reflect a 5 Fact Discovery Cutoff date of April 1, 2014. 6 7 IT IS SO ORDERED. 8 9 10 Dated: February 25, 2014 __________________________________ Magistrate The Honorable^Judge Howard R. Lloyd 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 -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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