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Adame v. Gillette

March 23, 2009

RICHARD ADAME, CONNIE G. BENDER, AND CONSTANCE DAVIS PLAINTIFF,
v.
PATRICIA K. GILLETTE IN SUPPORT OF BANK OF AMERICA, NATIONAL ASSOCIATION (ERRONEOUSLY SUED AS "BANK OF AMERICA") DEFENDANT.



The opinion of the court was delivered by: Judge: Hon. Susan Illston

STIPULATED REQUEST TO CHANGE TIME PURSUANT TO CIVIL L.R. 6-2 AND PROPOSED ORDER; DECLARATION OF SAME

STIPULATION

1. Pursuant to Civil Local Rule 6-2, the parties hereto through their respective attorneys of record hereby stipulate and agree to continue the Case Management Conference ("CMC") in this matter until June 12, 2009 or as soon as practicable thereafter as the availability of the Court's calendar permits.

2. The parties also stipulate and agree to continue the dates in the initial scheduling order to correspond to the new CMC date as follows:

May, 22, 2009, will be the last day to: Meet and confer re: initial disclosures, early settlement, ADR process selection, and discovery plan; File ADR Certification signed by Parties and Counsel; File either Stipulation to ADR Process or Notice of Need for ADR Phone Conference.

June 5, 2009, will be the last day to: File Rule 26(f) Report, complete initial disclosures or state objection in Rule 26(f) Report and file Case Management Statement per attached Standing Order re Contents of Joint Case Management Statement.

3. Both parties agree to the stipulation as indicated by their signatures below. The parties respectfully request that the Court approve the Stipulation, pursuant to Civil L.R. 6-2 and enter an Order thereupon. A form of proposed Order is filed herewith.

The parties make this stipulated request based on the facts set forth in the attached declaration of Patricia K. Gillette.

Respectfully submitted,

Dated: March 20, 2009

J. GARY GWILLIAM RANDALL E. STRAUSS GWILLIAM, IVARY, CHIOSSO, CAVALLI & BREWER

Randall E. Strauss Attorneys for Plaintiffs Richard Adame, Connie G. Bender and Constance Davis

Dated: March ...


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