Contreras et al v. Nationstar, LLC et al

Filing 129

STIPULATION and ORDER signed by Senior Judge Morrison C. England, Jr on 5/19/2021 EXTENDING deadlines as follows: Class Certification Amended Expert Report Deadline (for Plaintiffs) 09/03/2021; Plaintiffs' Deadline to File Motion for Cla ss Certification 09/22/2021; Class Certification Amended Expert Report Deadline (for Defendants) 10/20/2021; Defendants' Opposition to Plaintiffs' Motion for Class Certification 11/17/2021; Plaintiffs' Reply in Support of Motion for Class Certification 12/29/2021; Class-Certification Expert Discovery Cutoff 1/22/2022; Merits discovery cutoff 4/22/2022; Disclosure of Expert Witnesses 5/25/2022; Rebuttal Expert Reports 07/01/2022; Expert Discovery Cutoff 08/08/2022; and Deadline for Parties to File Dispositive Motions 09/02/2022. (Becknal, R)

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Derek W. Loeser, admitted pro hac vice
[e-mail]
Dean Kawamoto (Bar No. 232032)
[e-mail]
KELLER ROHRBACK L.L.P.
1201 Third Avenue, Suite 3200
Seattle, WA 98101
Tel.: [phone]
Fax: [phone]
Thomas E. Loeser (Bar No. 202724)
[e-mail]
HAGENS BERMAN SOBOL SHAPIRO LLP
1301 Second Avenue, Suite 2000
Seattle, WA 98101
Tel.: [phone]
Fax: [phone]
Attorneys for Plaintiffs
(Additional counsel listed on signature page)

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UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF CALIFORNIA
SACRAMENTO DIVISION

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EUGENIO and ROSA CONTRERAS,
WILLIAM PHILLIPS, TERESA BARNEY,
KEITH and TERESA MARCEL, SHERLIE
CHARLOT, and JENNIE MILLER, on behalf
of themselves and all others similarly situated,

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Plaintiffs,

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v.
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NATIONSTAR MORTGAGE LLC, a
Delaware Limited Liability Company;
SOLUTIONSTAR HOLDINGS LLC (N/K/A
XOME HOLDINGS LLC), a Delaware
Limited Liability Company; and
SOLUTIONSTAR FIELD SERVICES LLC, a
Delaware Limited Liability Company,

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Defendants

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No. 2:16-cv-00302-MCE-JDP
STIPULATED MOTION TO SET NEW
DISCOVERY DEADLINES AND ORDER
Action Filed:
Trial Date:

February 12, 2016
TBD

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Plaintiffs Eugenio and Rosa Contreras, William Phillips, Teresa Barney, Keith and Teresa

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Marcel, Sherlie Charlot, and Jennie Miller, on behalf of themselves and all others similarly situated

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(“Plaintiffs”) and Defendants Nationstar Mortgage LLC, Solutionstar Holdings LLC (n/k/a Xome

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Holdings LLC), and Solutionstar Field Services LLC (collectively “Nationstar”) (together, the

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“Parties”) by and through their respective counsel of record, hereby submit this Stipulated Motion To

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Set New Discovery Deadlines as set forth below.
Pursuant to the Parties’ January 29, 2021 Stipulated Motion, ECF No. 127, the Parties again

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attempted settlement discussions and requested an extension of all deadlines and a general stay of

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discovery other than production of ESI by Defendants while those negotiations were ongoing. The

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latest settlement negotiations have proven unsuccessful.

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During this time period, Defendants completed production of ESI. To accommodate the time

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period necessary to review documents recently produced by Defendants and complete the postponed

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depositions before preparing class certification papers, the Parties request that the case deadlines for

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class certification briefing and fact and expert discovery be extended by approximately 110 days from

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the dates contained in the Stipulated Motion to Extend Case Schedule Deadlines and Order, ECF No.

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127.

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This Stipulation is the tenth extension of certain deadlines on the case schedule and is made

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with good cause and without prejudice to, or waiver of, any rights or defenses otherwise available to

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the Parties in this action. The Parties therefore respectfully request that the Court grant this Stipulated

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Motion to set new discovery deadlines by extending all briefing and fact and expert discovery

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deadlines by 110 days from the dates contained in the prior Stipulated Motion to Extend Case

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Schedule Deadlines and Order as follows:

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Event

Current Deadlines

Proposed New or
Extended
Deadlines

05/14/2021

09/03/2021

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Class Certification Amended Expert Report
Deadline (for Plaintiffs)

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Stipulated Mot. to Set New Disc. Deadlines - 1

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06/04/2021

09/22/2021

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Plaintiffs’ Deadline to File Motion for Class
Certification

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Class Certification Amended Expert Report
Deadline (for Defendants)

07/02/2021

10/20/2021

Defendants’ Opposition to Plaintiffs’ Motion
for Class Certification

07/30/2021

11/17/2021

Plaintiffs’ Reply in Support of Motion for
Class Certification

09/10/2021

12/29/2021

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Class-Certification Expert Discovery Cutoff

09/24/2021

01/22/2022

Merits discovery cutoff

12/13/2021

04/22/2022

Disclosure of Expert Witnesses and
Information Required by Rule 26(a)(2)

02/04/2022

05/25/2022

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Rebuttal Expert Reports

03/14/2022

07/01/2022

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Expert Discovery Cutoff

04/18/2022

08/08/2022

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Deadline for Parties to File Dispositive
Motions

05/16/2022

09/02/2022

Deadline for Parties to File Motions
in Limine

Set by Court once
trial date is set

Set by Court once
trial date is set

Final Pretrial Conference

Set by Court once
trial date is set

Set by Court once
trial date is set

Trial Date

Set by Court once
trial date is set

Set by Court once
trial date is set

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DATED this 14th day of May 2021.
By /s/ Laura R. Gerber
Dean Kawamoto (Bar No. 232032)
[e-mail]
Derek W. Loeser, admitted pro hac vice
[e-mail]
Gretchen S. Obrist, admitted pro hac vice
[e-mail]
Laura R. Gerber, admitted pro hac vice
[e-mail]
Rachel E. Morowitz (Bar No. 326385)
[e-mail]
KELLER ROHRBACK L.L.P.
1201 Third Ave, Suite 3200
Seattle, WA 98101

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Stipulated Mot. to Set New Disc. Deadlines - 2

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Tel.: [phone]
Fax: [phone]

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Thomas E. Loeser (Bar No. 202724)
[e-mail]
Nick Styant-Browne, admitted pro hac vice
[e-mail]
HAGENS BERMAN SOBOL SHAPIRO L.L.P.
1301 Second Avenue, Suite 2000
Seattle, WA 98101
Tel.: [phone]
Fax: [phone]

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Attorneys for Plaintiffs
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DATED this 14 day of May 2021.
By /s/ Mary Kate Sullivan
John B. Sullivan (Bar No. 96742)
[e-mail]
Mary Kate Sullivan (Bar No. 180203)
[e-mail]
Erik Kemp (Bar No. 246196)
[e-mail]
SEVERSON & WERSON
One Embarcadero Center, Suite 2600
San Francisco, CA 94111
Tel.: [phone]
Fax: [phone]

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Attorneys for Defendants

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IT IS SO ORDERED.
Dated: May 19, 2021

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Stipulated Mot. to Set New Disc. Deadlines - 3