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Bridge Partners, A California Corporation v. Citibank

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


September 17, 2012

BRIDGE PARTNERS, A CALIFORNIA CORPORATION,
PLAINTIFF,
v.
CITIBANK, N.A., A NATIONAL BANKING
ASSOCIATION; JPMORGAN CHASE BANK, N.A.,
A NATIONAL BANKING ASSOCIATION; AND DOES 1
THROUGH 50, INCLUSIVE,
DEFENDANTS.

The opinion of the court was delivered by: William Alsup United States District Court Judge

ANDERIES & GOMES LLP Allan J. Gomes (SBN 225810) 2 Anne V. Leinfelder (SBN 230272) 601 Montgomery Street, Suite 888 3 San Francisco, California 94111 Telephone: (415) 217-8802 4 Facsimile: (415) 217-8803 agomes@andgolaw.com 5 aleinfelder@andgolaw.com 6 JOHN F. FRIEDEMANN (SBN 115632) jfriedemann@frigolaw.com 7 1 KYLE M. FISHER (SBN 127334) kfisher@frigolaw.com 8 FRIEDEMANN GOLDBERG LLP 420 Aviation Blvd., Suite 201 9 Santa Rosa, CA 95403 Telephone: (707) 543-4900 10 Facsimile: (707) 543-4910 11 Attorneys for Plaintiff BRIDGE PARTNERS, a California Corporation 12 13

STIPULATION AND [PROPOSED] ORDER RESETTING CASE MANAGEMENT CONFERENCE, EXTENDING TIME FOR THE PARTIES TO FILE ADR CERTIFICATIONS, FED. R. CIV.PROC. RULE 26(f) INITIAL DISCLOSURES, DISCOVERY PLAN AND JOINT CASE MANAGEMENT CONFERENCE STATEMENT

Pursuant to Local Rules 6-2, 7-12 and 16-2 this stipulation is entered into by and between laintiff BRIDGE PARTNERS ("Plaintiff"), Defendant CITIBANK, N.A. ("Citibank"), and 24 Defendant JPMORGAN CHASE BANK, N.A. ("Chase") (the "Parties"), through their respective 25 counsel of record.

relevant part Declaratory Judgment against Citibank, Chase and Doe Defendants. 4

FACTUAL RECITALS

1. On June 14, 2012, Plaintiff filed its Complaint in the above-captioned matter seeking in

2. On June 14, 2012, the Court granted Plaintiff's Request for a Temporary Restraining

Order, which was extended by the Court's Order on July 18, 2012, and is presently in place. 6

Injunction to September 27, 2012. The initial Case Management Conference in this matter is also 9 scheduled for September 27, 2012. 10

11 pleadings "be settled, as best as is possible." 12

13 amended complaint which would, among other things, add claims for conversion and declaratory 14 judgment against foreign banks AB Ukio Bankas, JSC Russian Standard Bank, Emirates NBD and 15

6. The Parties are presently required to file their ADR Certifications on or before

3. On July 18, 2012, the Court conducted a hearing on Plaintiff's Motion for Preliminary

Injunction. At the conclusion, the Court continued the hearing on Plaintiff's Motion for Preliminary 8

4. In the Court's order following the July 18, 2012 hearing, the Court requested that the

5. Prior to September 27, 2012 Plaintiff will be filing a motion for leave to file a first

VTB 24. 16

September 6, 2012. 18

7. The Parties are presently required to file their Rule 26(f) Initial Disclosures on or before September 20, 2012. 20

before September 20, 2012. 22

8. The Parties are presently required to file their Discovery Plan, pursuant to Rule 26 on or

9. The Parties are presently required to file their joint Case Management Conference

Statement on or before September 20, 2012. 24

25 date approximately four months after the presently scheduled date of September 27, 2012 and to 26 postpone the filing of the above ADR Certifications, Rule 26(f) Initial Disclosures, Discovery Plan 27 and joint Case Management Conference Statement accordingly. The Parties believe that this relief is 28

10. The Parties agree that it is appropriate to reset the Case Management Conference for a warranted in light of the fact that limited discovery related to Plaintiff's Motion for Preliminary 2

Injunction has already been conducted and Plaintiff's proposed first amended complaint adds as new 3 parties to the action foreign entities who will have to be served with the summons and complaint. 4

11. There have been no previous modifications or extensions of the deadlines to file ADR Certifications, Rule 26(f) Initial Disclosures, Discovery Plan or joint Case Management Conference 6

Statement, or changes to the Case Management Conference date, except that the Court sua sponte 7 reset the Case Management Conference from the original date of September 13, 2012 to September 8 27, 2012. 9

12. The Parties do not anticipate that an extension of these filing deadlines or resetting of

10 the Case Management Conference will substantially affect the schedule of this case. 11

STIPULATION

The Parties hereby stipulate as follows:

1. The Case Management Conference currently scheduled for September 27, 2012 is 14 continued until January 31, 2013 at 11:00am or a time and date convenient for the Court on or around 15 January 31, 2013. 16

2. The Parties may have up to and including January 10, 2013 in which to file their ADR Certifications. 18

3. The Parties may have up to and including January 24, 2013 in which to file their Rule 26(f) Initial Disclosures. 20

4. The Parties may have up to and including January 24, 2013 in which to file their Discovery Plan. 22

5. The Parties may have up to and including January 24, 2013 in which to file their joint

Case Management Conference Statement. 24

Filer's Attestation: Pursuant to Civil Local Rule 5-1 (i)(3) regarding signatures, John F. Friedemann 19 hereby attests that concurrence in the filing of this document has been obtained. 20 21

PURSUANT TO STIPULATION, IT IS SO ORDERED.

20120917

© 1992-2012 VersusLaw Inc.



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