The opinion of the court was delivered by: Honorable Donna M. Ryu United States Magistrate Judge
NANCY J. JOHNSON, CA STATE BAR NO. 111615 BERLINER COHEN 2 TEN ALMADEN BOULEVARD ELEVENTH FLOOR 3 SAN JOSE, CALIFORNIA 95113¶2233 TELEPHONE: (408) 286¶5800 4 FACSIMILE: (408) 998¶5388 email@example.com 5 ATTORNEYS FOR DEFENDANT AND CROSS¶DEFENDANT STEWART TITLE OF CALIFORNIA, INC. ERRONEOUSLY SUED HEREIN AS STEWART TITLE OF CALIFORNIA 7 8
STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR STEWART TITLE OF CALIFORNIA, INC AND CROSS¶ CLAIMANTS TO PROVIDE A JOINT DISCOVERY LETTER; AND DECLARATION [L.R. 6¶2] AND RELATED CROSS¶ACTION. 22 23
WHEREAS, on March 9, 2012, this Court denied Stewart Title's Motion to Dismiss Cross¶Claim without prejudice and issued its Notice of Reference and Order Re: Discovery 3 Procedures. 4
This Stipulation is made pursuant to Local Rule 6¶2 by and between Cross¶Claimants The Loan Experts Corporation dba All American Finance and Hormoz Nazari ("Cross¶Claimants") 25 and Cross¶Defendant Stewart Title of California, Inc. ("Stewart Title") through their respective 26 attorneys.
WHEREAS, On March 13, 2012, Stewart Title and Cross¶Claimants met and conferred 5 as ordered; 6
WHEREAS, Cross¶Claimants have produced documents, a Second Supplemental Initial Disclosure, and intend to produce additional documents this week; 8 WHEREAS, Stewart Title has not had sufficient time to review the documents recently 9 produced and will not have sufficient time to review additional documents before the Court's 10 Friday, March 16, 2012, deadline to file a joint letter regarding the discovery dispute; 11
WHEREAS, Stewart Title and Cross¶Claimants intend to continue to meet in good faith 12 in an attempt to resolve the pending death discovery dispute and need additional time to 13 complete the meet and confer process; 14
NOW, THEREFORE, THE PARTIES HEREBY STIPULATE AND AGREE, through 15 their respective counsel of record, that the court should extend the period in which to file their 16 joint discovery letter with the Court to March 30, 2012. 17
DECLARATION OF CHRISTIAN E. PICONE
I, Christian E. Picone, declare:
1. I am an attorney licensed to practice in the state of California, I am admitted to 4 practice before this honorable court, and I am an associate at the law firm of Berliner Cohen. I, 5 along with Nancy J. Johnson, represent Cross¶Defendant Stewart Title of California, Inc. in the 6 above referenced case. 7
2. On March 13, 2012, Stewart Title and Cross¶Claimants, through counsel, met and 8 conferred. 9
3. Cross¶Claimants recently produced documents and are in the process of producing 10 ...