Filed: Jul. 18, 2019
Latest Update: Jul. 18, 2019
Summary: STIPULATION TO CONTINUE DEADLINE TO FILE DISPOSITIONAL PAPERS PURSUANT TO LOCAL RULE 160 AND ORDER MORRISON C. ENGLAND, JR. , District Judge . Pursuant to Civil Local Rule 143, Plaintiff Mike Cortes ("Plaintiff") and Defendant National Credit Adjusters, L.L.C. ("Defendant") (collectively, the "Parties"), by and through their respective counsel, stipulate as follows: WHEREAS, on January 18, 2019, the Parties participated in a mediation with Martin Quinn, Esq., at JAMS in San Francisco, Cali
Summary: STIPULATION TO CONTINUE DEADLINE TO FILE DISPOSITIONAL PAPERS PURSUANT TO LOCAL RULE 160 AND ORDER MORRISON C. ENGLAND, JR. , District Judge . Pursuant to Civil Local Rule 143, Plaintiff Mike Cortes ("Plaintiff") and Defendant National Credit Adjusters, L.L.C. ("Defendant") (collectively, the "Parties"), by and through their respective counsel, stipulate as follows: WHEREAS, on January 18, 2019, the Parties participated in a mediation with Martin Quinn, Esq., at JAMS in San Francisco, Calif..
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STIPULATION TO CONTINUE DEADLINE TO FILE DISPOSITIONAL PAPERS PURSUANT TO LOCAL RULE 160 AND ORDER
MORRISON C. ENGLAND, JR., District Judge.
Pursuant to Civil Local Rule 143, Plaintiff Mike Cortes ("Plaintiff") and Defendant National Credit Adjusters, L.L.C. ("Defendant") (collectively, the "Parties"), by and through their respective counsel, stipulate as follows:
WHEREAS, on January 18, 2019, the Parties participated in a mediation with Martin Quinn, Esq., at JAMS in San Francisco, California;
WHEREAS, on February 5, 2019, the Parties executed a binding Term Sheet setting out an agreement to settle all claims in this action on a class basis;
WHEREAS, on February 6, 2019, upon stipulation of the Parties and notice of the settlement, the Court vacated all remaining pretrial deadlines and ordered the Parties to file dispositional papers pursuant to Local Rule 160 by February 28, 2019 (Dkt. No. 35);
WHEREAS, on June 28, 2019, upon stipulation of the Parties, the Court extended the Parties' deadline to file dispositional papers pursuant to Local Rule 160 to June 28, 2019 (Dkt. 37);
WHEREAS, the Parties have made significant progress but need more time to finalize the full class settlement agreement (along with all of the relevant exhibits thereto, i.e., long form and short-form notice documents, proposed final approval and judgment orders, etc.);
WHEREAS, once the full class settlement agreement is executed, Plaintiff intends to file a motion for preliminary approval of the settlement and provide the Court with a copy of the executed class settlement agreement at that time;
WHEREAS, due to the extensive time needed to draft (and negotiate) the full class action settlement agreement and the motion for preliminary approval, the Parties anticipate that they will be able to execute the class action settlement agreement and that Plaintiff will be able to file a motion for preliminary approval by August 9, 2019;
NOW THEREFORE, IT IS STUPULATED AND AGREED by the Parties, by and through their counsel, that the Parties' deadline to file dispositional papers pursuant to Local Rule 160 shall be extended to August 9, 2019.
Dated: June 28, 2019 Respectfully submitted,
BURSOR & FISHER, P.A.
By: /s/ Yeremey
Yeremey Krivoshey
L. Timothy Fisher (State Bar No. 191626)
Yeremey Krivoshey (State Bar No. 295032)
1990 North California Boulevard, Suite 940
Walnut Creek, CA 94596
Telephone: (925) 300-4455
Facsimile: (925) 407-2700
E-Mail: ltfisher@bursor.com
ykrivoshey@bursor.com
BURSOR & FISHER, P.A.
Scott A. Bursor (State Bar No. 276006)
2665 S. Bayshore Dr., Suite 220
Miami, FL 33133-5402
Telephone: (305) 330-5512
Facsimile: (305) 676-9006
E-Mail: scott@bursor.com
Attorneys for Plaintiff
Dated: June 28, 2019. SESSIONS, FISHMAN, NATHAN & ISRAEL, L.L.P.
By: /s/ James K. Schultz
James K. Schultz
James K. Schultz (State Bar No. 309945)
Debbie P. Kirkpatrick (State Bar No. 207112)
1545 Hotel Circle South, Suite 150
San Diego, CA 92108
Telephone: (619) 758-1891
Facsimile: (619) 296-2013
E-Mail: jschultz@sessions.legal
dkirkpatrick@sessions.legal
Attorneys for Defendant National Credit Adjusters, LLC
ORDER
IT IS HEREBY ORDERED the Parties' deadline to file dispositional papers pursuant to Local Rule 160 shall be extended to August 9, 2019.
IT IS SO ORDERED.
