Lucy H. Koh
KYRA A. KAZANTZIS (STATE BAR NO. 154612
JAMES F. ZAHRADKA (STATE BAR NO. 196822)
ANNETTE D. KIRKHAM (STATE BAR NO. 217958)
NADIA AZIZ (STATE BAR NO. 252966)
KATHERINE M. LEHE (STATE BAR NO. 273472)
FAIR HOUSING LAW PROJECT
LAW FOUNDATION OF SILICON VALLEY
Attorneys for Plaintiffs DAVID and BARBARA WATTS
STIPULATION AND [PROPOSED] ORDER
TO EXTEND THE DISPOSITIVE MOTION
DEADLINE BY 21 DAYS
As Modified by Court
Plaintiffs David and Barbara Watts and Defendants JP Morgan Chase Bank, N.A., U.S. Bank, N.A. and California Reconveyance Corporation ("the Parties") submit this Joint Stipulation to Extend the Dispositive Motion deadline by twenty-one days. Plaintiffs are represented by Fair Housing Law Project of the Law Foundation of the Silicon Valley. Defendants are represented by Bryan Cave, LLP.
WHEREAS, the Parties have been diligent in their prosecution and defense of the claims asserted in this action.
WHEREAS, the Parties have not previously sought any extension of time or modification of the Court's Case Management Order.
WHEREAS, the Parties are engaged in informal settlement discussions to resolve this matter amicably, and the Parties agree that judicial economy and the interests of the Parties in avoiding unnecessary expenses would be best served and promoted by briefly extending the time required for the Parties to file their respective dispositive motions
NOW, THEREFORE, the undersigned Parties stipulate that the time for the Parties to file dispositive motions be extended by twenty-one days to July 6, 2012;
NOW, THEREFORE, the undersigned Parties stipulate that the hearings on any dispositive motions shall be continued twenty-one days to August 9, 2012,
Respectfully submitted,
FAIR HOUSING LAW PROJECT
____________________________
Annette D. Kirkham
Attorneys for Plaintiffs
BRYAN CAVE LLP
____________________________
Goli Mahdavi
Attorneys for Defendants, JP MORGAN CHASE BANK, NA,
US BANK NATIONAL ASSOCIATION, and CALIFORNIA
RECONVEYANCE CORPORATION,
ATTESTATION PURSUANT TO GENERAL ORDER 45
I, Annette D, Kirkham, attest that concurrence in the filing of this document has been obtained from each of the signatories. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on June 5, 2012, at San Jose, California.
____________________________
Annette D. Kirkham
[PROPOSED ORDER]
Pursuant to the Stipulation to Extend Time to File Dispositive Motions,
IT IS HEREBY ORDERED THAT:
1. The Parties shall have until july 5, 2012 to file dispositive motions
2. Dispositive motions shall be heard on August 9, 2012, at 1:30 p.m.
____________________________
Honorable Lucy H. Koh
United States District Judge