Bird v. Wells Fargo Bank

Filing 33

STIPULATION and ORDER GRANTING the parties' request to continue the Motion to Compel and for Sanctions, document 30 , currently noticed for hearing on 5/26/2016, which hearing will now be held on 6/1/2017 at 10:00 AM in Courtroom 10 (EPG) befor e Magistrate Judge Erica P. Grosjean. Telephonic appearances are granted with the parties to use the following dial-in number and passcode: 1-888-251-2909; passcode 1024453. The Court further grants the request that the page length of the joint statement be extended to 30 pp. in order to accommodate the high number of issues addressed in the motion. Order signed by Magistrate Judge Erica P. Grosjean on 5/18/2017. (Rooney, M)

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DANIEL J. CRAVENS (SBN 207859)
CRAVENS & ASSOCIATES
516 W. Shaw Avenue, Suite 200
Fresno, CA 93704
Telephone: [phone]
Facsimile: 855.273.3797

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Yosef Peretz (SBN 209288)
[e-mail]
Sumy Kim (SBN 290082)
[e-mail]
PERETZ & ASSOCIATES
22 Battery Street, Suite 200
San Francisco, CA 94111
Telephone: [phone]
Facsimile: [phone]
Attorneys for Plaintiff KIMBERLY SUE BIRD
UNITED STATES DISTRICT COURT

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EASTERN DISTRICT

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KIMBERLY SUE BIRD,
Plaintiff,

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v.
WELLS FARGO BANK., a California
Corporation, and Does I-XX, inclusive
Defendants.

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Civil Case No. 1:16-CV-01130-DAD-EPG
STIPULATION TO CONTINUE MOTION
TO COMPEL HEARING AND REQUEST
TO EXPAND PAGE LENGTH OF JOINT
REPORT; ORDER THEREON
Date:
May 26, 2017
Time:
10:00 a.m.
Courtoom: 10

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WHEREAS on April 28, 2017 Plaintiff Kimberly Sue Bird (“Bird”) noticed her motion
to compel discovery and for sanctions for hearing on May 26, 2017 at 10 a.m. (ECF 30);
WHEREAS the Plaintiff’s motion addresses multiple issues including Plaintiff’s
contention that Defendant has failed to comply with the Court’s March 31, 2017 discovery
order in several particulars; failed to perform an adequate search of ESI; and failed to provide
appropriate FRCP 30(b)(6) witnesses and testimony;
WHEREAS the FRCP 30(b)(6) deposition that forms the basis of a portion of Plaintiff’s
contentions was held on May 15, 2017;
STIPULATION TO CONTINUE MOTION TO COMPEL HEARING AND REQUEST TO EXPAND PAGE LENGTH OF JOINT REPORT

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WHEREAS the parties agree in order to provide both parties with adequate time to

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prepare its response to Plaintiff’s contentions concerning Defendant’s 30(b)(6) deposition, that

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the (1) Plaintiff will provide Defendant with a draft of her portion of the Joint Statement on

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May 19, 2017; (2) Defendant will provide Plaintiff with a draft of its position on May 25, 2017;

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(3) the deadline for filing the joint statement be continued until May 26, 2017; (4) the hearing
on Plaintiff’s motion to compel and for sanctions be continued until June 1, 2017 at 10 a.m. in
Courtroom 10.

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WHEREAS the parties request that the page length of the joint statement be extended to
30 pp. in order to accommodate the high number of issues addressed in the motion.

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Dated: May 17, 2017

CRAVENS & ASSOCIATES

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By: __/s/ Daniel J. Cravens______
Attorneys for Plaintiff
KIMBERLY SUE BIRD

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Dated:

SHEPPARD MULLIN RICHTER & HAMPTON LLP

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By: ___/s/ Hilary Habib________
Attorneys for Defendant
WELLS FARGO BANK

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IT IS SO ORDERED.
Dated:

May 18, 2017

/s/

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UNITED STATES MAGISTRATE JUDGE

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STIPULATION TO CONTINUE MOTION TO COMPEL HEARING AND REQUEST TO EXPAND PAGE LENGTH OF JOINT REPORT

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