BUCHALTER NEMER

A PR O FE S S ION AL COR P OR AT IO N

SAN FRANCI SCO

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CASE NO. S-04-1855 FCD 

BUCHALTER NEMER 

A Professional Corporation 

SARAH K. ANDRUS (#174323) 

MIA S. BLACKLER (#188112) 

333 Market Street, 25th Floor 

San Francisco, CA 94105-2130 

Telephone: (415) 227-0900 / Facsimile: (415) 227-0770 

Attorneys for Defendants 

AMERIQUEST MORTGAGE COMPANY AND 

TOWN & COUNTRY TITLE SERVICES, INC. 

UNITED STATES DISTRICT COURT 

EASTERN DISTRICT OF CALIFORNIA - SACRAMENTO DIVISION 

KEITH T. TOWNS, 

Plaintiff, 

vs. 

AMERIQUEST MORTGAGE COMPANY, 

TOWN AND COUNTRY TITLE 

SERVICES, INC., NORTH AMERICAN 

TITLE COMPANY, 

Defendants. 

CASE NO. S-04-1855 FCD PAN 

JOINT STIPULATION AND ORDER TO 

CONTINUE DEADLINES RE PRETRIAL 

CONFERENCE STATEMENT, 

PRETRIAL CONFERENCE AND 

RELATED ORDER TO SHOW CAUSE 

“AS MODIFIED” 

Plaintiff Keith T. Towns (“Towns”) and Defendant Ameriquest Mortgage 

Company (“Ameriquest”) hereby stipulate as follows: 

1. That the pretrial conference currently scheduled for March 31, 2006, may be 

continued for a period of approximately three weeks. 

2. That the parties’ joint pretrial conference statement deadline be continued for 

approximately two weeks; and 

3. That the Order to Show Cause hearing be continued to the date selected for the 

continued pretrial conference. 

Good cause exists for a continuance of the above-referenced deadlines. The parties 

mediated this matter on March 13, 2006, at which the parties made progress on settlement 

Case 2:04-cv-01855-KJM-EFB Document 29 Filed 03/22/06 Page 1 of 3
BUCHALTER NEMER

A PR O FE S S ION AL COR P OR AT IO N

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CASE NO. S-04-1855 FCD 

negotiations. The potential settlement contemplates a refinancing of Towns’ residential mortgage 

loan with Ameriquest. Accordingly, Towns needs time to work with potential lenders to assess 

his lending ability, and the parties need to agree on the settlement amounts at issue. The 

mediation was originally scheduled for March 6, 2006, through the Court’s VDRP Program, 

Richard Pachter, Esq. presiding as mediator. Mr. Pachter became unexpectedly unavailable on 

March 6, 2006, and March 13 , 2006 was the earliest available date thereafter. 

Given that the parties are working towards settlement of this matter, the parties 

respectfully suggest that their efforts are best spent on settlement for the next couple of weeks 

rather than trial preparations to minimize party and judicial resources. 

DATED: March __, 2006 BUCHALTER NEMER, 

A Professional Corporation 

By: 

MIA S. BLACKLER 

Attorneys for Defendants 

AMERIQUEST MORTGAGE COMPANY and 

TOWN & COUNTRY TITLE SERVICES, INC. 

DATED: March __, 2006 LAW OFFICES OF LEWIS NELSON 

By: 

LEWIS NELSON 

Attorneys for Plaintiff 

KEITH T. TOWNS 

/// 

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CASE NO. S-04-1855 FCD 

ORDER 

1. The pretrial conference currently scheduled for March 31, 2006 is VACATED 

and RESET to Friday, May 19, 2006 at 1:30 p.m.; 

2. The parties’ joint pretrial conference statement shall be filed on or before 

May 12, 2006; and 

3. The Order to Show Cause hearing currently scheduled for March 31, 2006 is 

VACATED and RESET to Friday, May 19, 2006 at 1:30 p.m. Defendant’s response to the Order 

to Show Cause shall be filed on or before May 12, 2006; 

4. The court trial set for May 23, 2006 is VACATED and shall be RESET, if 

necessary, at the final pretrial conference. 

IT IS SO ORDERED 

Dated: March 22, 2006 /s/ Frank C. Damrell Jr. 

 THE HONORABLE FRANK C. DAMRELL, JR. 

 JUDGE OF THE EASTERN DISTRICT COURT 

Case 2:04-cv-01855-KJM-EFB Document 29 Filed 03/22/06 Page 3 of 3