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THEODORE E. BACON (CA Bar No. 115395)

tbacon@adorno.com

PATRICK A. CATHCART (CA BarNo. 65413)

pcathcart@adorno.com

AMY L. MORSE (CA Bar No. 092135)

amorse@adorno.com

REGINALD ROBERTS, JR. (CA Bar No. 216249)

rroberts@adorno.com

ADORNO YOSS ALVARADO & SMITH

A Professional Corporation

633 W. Fifth Street, Suite 1100

Los Angeles, CA 90071

Tel: (213) 229-2400

Fax: (213) 229-2499

Attorneys for Defendants

JPMorgan Chase Bank, N.A., an acquirer of

certain assets and liabilities of Washington

Mutual Bank from the FDIC Acting as

Receiver, and California Reconveyance

Company

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORNIA

KA TY SULLIVAN, also known as KA TY

MARIE SULLIVAN,

Plaintiff,

v.

WASHINGTON MUTUAL BANK, FA, JP

MORGAN CHASE BANK, National

Association,

BANK OF AMERICA, National Association,

LASALLE BANK, National Association

CALIFORNIA RECONVEYANCE

COMPANY; and Does 1 through 50, inclusive,

Defendants.

CASE NO.: CV 09-2161 EMC

JOINT STIPULATION TO CONTINUE

CASE MANAGEMENT CONFERENCE

Action Filed: April 22, 2009

California Superior Court, San Francisco

Case No.: CGC 09-487634

This Stipulation is entered into by all of the parties who have appeared before the Court in

the above entitled action, by and through each of their counsel of record, being J. Brian McCauley,

Esq., for Plaintiff Katy Sullivan, and Reginald Roberts, Jr., Esq. of the firm of Adorno Yoss

1

JOINT STIPULATION TO CONTIN CASE MANAGEMENT CONFERENCE .CV 09-2161 EMC

2037941

Case 3:09-cv-02161-EMC Document 43 Filed 02/01/10 Page 1 of 3
Alvarado & Smith, for Defendants JPMorgan Chase Bank, NA, Bank of America, NA, and

California Reconveyance Company.

This stipulation is respectfully submitted as an application to continue the Further Case

Management Conference to March 5, 2010.

This application and stipulation is made upon the following facts:

1. Mediation in this matter was conducted after the submittal of Mediation Statements

by both sides, before Mediator J. Daniel Sharp, on Thursday, December 10,2009;

2. The matter was mediated for a half day, but was unsuccessfuL. The mediating

Defendants requested further information from Plaintiff regarding financial and income matters;

which were agreed to be requested in addition to certain information provided in preparation for

mediation. Such additional information is believed to be constructive to the settlement process.

3. All parties to the mediation and this litigation (except Washington Mutual Bank, NA,

which has not yet made an appearance in this action as a result of having been seized and sold

pursuant to Federal Deposit Insurance Corp. (FDIC) action), are in favor of this application and

concur in the request;

4. As a result of the needed period to obtain additional financial documentation in a

form acceptable to Defendants, the Parties submitted, and this Court granted a request for an

extension to and including March 1, 2010 for the completion of mediation before 1. Daniel Sharp,

appointed mediator.

5. The parties now request that the Court Continue the Further Case Management

Conference ("CMC"), currently scheduled for February 3,2010, at 2:30 in Courtroom C or the

III

III

III

III

III

III

III

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JOINT STIPULATION TO CONTIN CASE MANAGEMENT CONFERENCE CV 09-2161 EMC

2037941

Case 3:09-cv-02161-EMC Document 43 Filed 02/01/10 Page 2 of 3
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above-captioned Court, to March 5, 2010. The parties request this continuance of the CMC in order

to permit time to complete the mediation process before returning to court for the CMC.

Dated: January 29,2010

By:

Dated; January 29,2010

By:

Respectfully submitted,

Law Offices of 1. Brian McCauley

Professional Corporation

J. Brian cauley, Esq.

Attorney r Plaintiff

KA TY SULLIVAN

Respectfully submitted,

2037941

3

JOINT STIPULATION TO CONTIN CASE MANAGEMENT COj\'FERENCE CV 09-2161 EMC

Case 3:09-cv-02161-EMC Document 43 Filed 02/01/10 Page 3 of 3