Ramirez et al v. Greenpoint Mortgage Funding, Inc.

Filing 157

STIPULATION AND ORDER for extension of class certification deadlines. The motion for class certification shall be heard on 06/28/10 at 10:00 AM. Signed by Judge Thelton E. Henderson on 02/25/10. (rbe, COURT STAFF) (Filed on 2/25/2010)

1 RAOUL D. KENNEDY (Bar No. 40892) SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP 2 Four Embarcadero Center, Suite 3800 San Francisco, California 94111-4144 3 Telephone: [phone] Facsimile: [phone] 4 Email: [e-mail] 5 ANAND S. RAMAN (admitted pro hac vice) AMANDA M. RAINES (admitted pro hac vice) 6 COLIN D. FORBES (admitted pro hac vice) SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP 7 1440 New York Avenue N.W. Washington, D.C. 20005-2111 8 Telephone: [phone] Facsimile: [phone] 9 Email: [e-mail] 10 Counsel for Defendant GREENPOINT MORTGAGE FUNDING, INC. 11 [Additional counsel appear on signature page.] 12 13 14 15 16 17 ANA RAMIREZ and ISMAEL RAMIREZ, on ) behalf of themselves and all others similarly ) ) 18 situated, ) ) 19 Plaintiffs, ) ) 20 ) vs. 21 ) ) 22 ) GREENPOINT MORTGAGE FUNDING, ) 23 INC., ) ) 24 ) Defendant. ) 25 26 27 28
JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF CLASS CERTIFICATION DEADLINES, Case No. C08-00369TEH

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION No. C 08-00369 TEH CLASS ACTION JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF CLASS CERTIFICATION DEADLINES Judge: Honorable Thelton E. Henderson Expedited Treatment Requested

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Pursuant to Civil Local Rules 6-2 and 7-12, Defendant GreenPoint Mortgage Funding,

2 Inc. and Plaintiffs Ana Ramirez, Ismael Ramirez, and Jorge Salazar (collectively, the "Parties") 3 hereby respectfully request that this Court extend the deadlines for the Parties to file their 4 respective class certification papers by fourteen days. The current briefing schedule was set by 5 Court Order [Docket No. 155]. 6 In support of this Motion, the Parties represent that they have been diligently working to

7 complete discovery relevant to class certification. Depositions of the Plaintiffs are scheduled for 8 March 16, 2010, March 17, 2010, and March 23, 2010, which were the earliest dates the 9 Plaintiffs were available. 10 A brief extension of time for the filing of the Parties' class certification papers is

11 necessary in the interests of the efficient administration of justice, and to ensure a fair and 12 orderly completion of class discovery and sufficient time for briefing regarding class 13 certification. 14 A proposed Order is attached. SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP /s/ Anand S. Raman Anand S. Raman (admitted pro hac vice) Amanda M. Raines (admitted pro hac vice) Colin D. Forbes (admitted pro hac vice) 1440 New York Avenue, N.W. Washington, DC 20005 Telephone: [phone] Fax: [phone] Raoul D. Kennedy (CA SBN 40892) Four Embarcadero Center, Suite 3800 San Francisco, California 93111-6400 Telephone: [phone] Fax: [phone] Attorneys for Defendant

15 DATED: February 24, 2010 16 17 18 19 20 21 22 23 24 25 26 27 28

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JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF CLASS CERTIFICATION DEADLINES, Case No. C08-00369TEH

1 DATED: February 24, 2010 2 3 4 5 6 7 8 9 10 Counsel for Plaintiffs:

RODDY KLEIN & RYAN CHAVEZ & GERTLER LLP MILLER LAW LLC NATIONAL CONSUMER LAW CENTER BONNETT, FAIRBOURN, FRIEDMAN & BALINT, P.C. /s/ Gary Klein Gary Klein Attorneys for Plaintiffs

BONNETT, FAIRBOURN, FRIEDMAN 11 & BALINT, P.C. Andrew S. Friedman (admitted pro hac vice) 12 Wendy J. Harrison (CA SBN 151090) 13 2901 North Central Avenue, Suite 1000 Phoenix, Arizona 85012 14 Tel: [phone] Fax: [phone] MILLER LAW LLC 16 Marvin A. Miller Lori A. Fanning (admitted Pro Hac Vice) 17 115 South LaSalle Street, Suite 2910 Chicago, IL 60603 18 Tel: [phone] CHAVEZ & GERTLER LLP 21 Mark A. Chavez (CA SBN 90858) Nance F. Becker (CA SBN 99292) 22 Dan Gildor (CA SBN 223027) 23 42 Miller Avenue Mill Valley, California 94941 [phone] 24 Tel: Fax: [phone] 27 28
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RODDY KLEIN & RYAN Gary Klein (admitted pro hac vice) Shennan Kavanagh 727 Atlantic Avenue Boston, MA 02111-02810 Telephone: [phone], ext. 15 Facsimile: 617-357-5030 NATIONAL CONSUMER LAW CENTER Stuart T. Rossman (To be admitted Pro Hac Vice) Charles Delbaum (To be admitted Pro Hac Vice) 77 Summer Street, 10th Flr. Boston, MA 02141 Tel: [phone] Fax: [phone]

JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF CLASS CERTIFICATION DEADLINES, Case No. C08-00369TEH

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[PROPOSED] ORDER Upon the stipulation of the Parties, and good cause appearing, the below schedule is

3 adopted by the Court: 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
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Pretrial or Trial Event Motion for Class Certification Response to Motion for Class Certification Plaintiffs' Reply on Motion for Class Certification Expert Discovery on Merits Last day for hand-serving motions and filings (other than Motions in Limine) Non-Expert Discovery Cut-Off Date Parties to meet and confer to prepare joint final pretrial conference statement and proposed order and coordinated submission of trial exhibits and other material Filing Joint Pretrial Conference Statement and Proposed Order Lodging exhibits and other trial materials

Requested Deadline March 15, 2010 April 29, 2010 May 31, 2010 Parties meet and confer following resolution of class certification motion Parties meet and confer following resolution of class certification motion Parties meet and confer following resolution of class certification motion Parties meet and confer following resolution of class certification motion Parties meet and confer following resolution of class certification motion Parties meet and confer following resolution of class certification motion Parties meet and confer following resolution of class certification motion Parties meet and confer following resolution of class certification motion Parties meet and confer following resolution of class certification motion Parties meet and confer following resolution of class certification motion

Last day to serve and file briefs on disputed issues of law, including procedural and evidentiary issues Serve and file requested voir dire, jury instructions and forms of verdict Serve and file statements designating deposition excerpts, form interrogatory answers and responses to requests for admission to be offered at trial other than for impeachment or rebuttal Last day to meet and confer regarding objections to evidence

JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF CLASS CERTIFICATION DEADLINES, Case No. C08-00369TEH

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Pretrial or Trial Event Final Pretrial Conference and Hearing on Motions in Limine Trial Date

Requested Deadline Parties meet and confer following resolution of class certification motion Parties meet and confer following resolution of class certification motion

PURSUANT TO STIPULATION, IT IS SO ORDERED. Plaintiffs' motion for class certification shall be heard on June 28, 2010, at 10:00 AM, unless otherwise ordered. Hon. Thelton E. Henderson United States District Court Judge

02/25/10 12 Dated: _________________________ 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
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