Crider v. Wachovia Corporation et al

Filing 14

STIPULATION AND ORDER re 10 Stipulation, filed by Wachovia Mortgage, FSB, Wachovia Financial Services Inc., Wachovia Corporation, Wachovia Commercial Mortgage, Inc, Wachovia Mortgage Corporation Initial Case Management Conference set for 3/18/2009 01:30 PM.. Signed by Judge Edward M. Chen on 12/10/08. (bpf, COURT STAFF) (Filed on 12/10/2008)

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Case 3:08-cv-04288-EMC Document 10 Filed 11/26/2008 Page 1 of 4 1 2 3 4 5 6 7 8 9 10 11 12 13 14 COUNSEL FOR PLAINTIFFS AND PROPOSED CLASS LISTED ON NEXT PAGE MALCOLM A. HEINICKE (State Bar No. 194174) TREVOR D. DRYER (State Bar No. 247826) MUNGER, TOLLES & OLSON LLP 560 Mission Street Twenty-Seventh Floor San Francisco, CA 94105-2907 Telephone: (415) 512-4000 Facsimile: (415) 512-4077 E-mail: Malcolm.Heinicke@mto.com Attorneys for Defendants WACHOVIA CORP. ET AL UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ROBERT CRIDER, on behalf of himself and others similarly situated, Plaintiff, CASE NO. CV 08-04288-EMC 15 vs. 16 17 18 19 20 21 22 23 24 25 26 27 28 6487262.1 STIPULATION AND PROPOSED ORDER RE: CONTINUANCE OF INITIAL CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES The Honorable Edward M. Chen Date: December 17, 2008 Time: 1:30 p.m. Courtroom: C, 15h Floor Proposed Date: March 18, 2009 WACHOVIA CORPORATION, a corporation, WACHOVIA MORTGAGE CORPORATION, a corporation, WACHOVIA COMMERCIAL MORTGAGE, INC., a corporation, WACHOVIA FINANCIAL SERVICES, INC., WACHOVIA MORTGAGE, FSB, and entity form unknown, WACHOVIA, an entity form unknown, and, DOES 1 through 100 inclusive, Defendants. STIPULATION AND PROPOSED ORDER, CASE NO. 08-04288-EMC Case 3:08-cv-04288-EMC Document 10 Filed 11/26/2008 Page 2 of 4 1 2 3 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 PETER M. HART (SBN 198691) LAW OFFICES OF PETER M. HART 13952 Bora Bora Way, F-320 Marina Del Rey, CA 90292 Telephone: (310) 478-5789 Facsimile: (509) 561-6441 Email: hartpeter@msn.com LARRY W. LEE (SBN 228175) DIVERSITY LAW GROUP 444 S. Flower Street, Suite 1370 Los Angeles, CA 90071 Telephone: (213) 488-6555 Facsimile: (213) 488-6554 KENNETH H. YOON (SBN 198443) LAW OFFICES OF KENNETH H. YOON One Wilshire Boulevard, Suite 2200 Los Angeles, CA 90017 Telephone: (213) 612-0988 Facsimile: (213) 947-1211 kyoon@yoon-law.com Attorneys for Plaintiff ROBERT CRIDER and those similarly situated // // 6487262.1 STIPULATION AND PROPOSED ORDER, CASE NO. 08-04288-EMC Case 3:08-cv-04288-EMC Document 10 Filed 11/26/2008 Page 3 of 4 1 2 3 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 6487262.1 WHEREAS, Plaintiff Robert Crider ( Plaintiff ) brings this putative wage and hour class and collective action against Defendant Wachovia Mortgage, FSB ( Defendant ) and other affiliated entities (Plaintiff and Defendant shall hereinafter be referred to as the parties ); WHEREAS, the parties exchanged substantial information on the proposed class and then following further discussions, mediated the case in front of David A. Rotman, Esq. on October 7, 2008, and through this mediation, they reached a settlement agreement which the parties will shortly be presenting to the Court for preliminary approval; WHEREAS, the settlement reached by the parties will also address and result in the dismissal of Sones v. World Mortgage Co. et al., No. 08-04811-CRB, which is currently pending before the Honorable Charles Breyer of this Court; WHEREAS, in light of this settlement and the parties plan to present this settlement for preliminary approval, they respectfully submit that a continuance of the Initial Case Management Conference and the associated deadlines for ninety (90) days would conserve judicial resources and avoid unnecessary expense to the parties; WHEREAS, the parties respectfully request that the Court re-schedule the casemanagement conference for a date on or after Wednesday, March 18, 2009 and continue the associated case management deadlines; WHEREAS, the parties have executed a term sheet outlining the terms of the settlement; WHEREAS, the parties plan to file their motion for preliminary approval of the class settlement on or before January 9, 2008; WHEREAS, the parties plan to file consents to proceed before the Honorable Edward M. Chen for all purposes in this matter; IT IS HEREBY STIPULATED by the parties, through their counsel of record, that the Initial Case Management Conference in this matter is continued to March 18, 2009 at 1:30 p.m., and the associated dates are continued accordingly such that they shall precede the rescheduled Case Management Conference. -1- STIPULATION AND PROPOSED ORDER, CASE NO. 08-04288-EMC Case 3:08-cv-04288-EMC Document 10 Filed 11/26/2008 Page 4 of 4 1 2 DATED: November 26, 2008 DIVERSITY LAW GROUP By: /s/ Larry W. Lee LARRY W. LEE Attorneys for Plaintiff Robert Crider 3 4 5 6 By: /s/ 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 DATED: November 26, 2008 MUNGER, TOLLES & OLSON LLP Malcolm A. Heinicke MALCOLM A. HEINICKE Attorneys for Defendant World Savings, Inc. I, Malcolm A. Heinicke, attest that I have obtained concurrence from Larry W. Lee in the filing of this Stipulation And [Proposed] Order Re: Continuance of Initial Case Management Conference and Related Deadlines. See N.D. Cal. General Order 45 10(B). GOOD CAUSE APPEARING AND PURSUANT TO STIPULATION, IT IS SO ORDERED: The Initial Case Management Conference is continued to March 18, 2009 at 1:30 p.m., or to ___________________, 2009; and Joint CMC Statement due March 11, 2009. The deadlines associated with the Initial Case Management Conference will track the continued date. Date: December 10, 2008 UNIT ED S _______________________________ Hon. Edward M. Chen D S DISTRICT TE C TA RT U O 28 6487262.1 N F D IS T IC T O R -2- STIPULATION AND PROPOSED ORDER, CASE NO. 08-04288-EMC A 27 ER C LI FO 26 dwar Judge E en d M. Ch R NIA RDERE S SO O IED IT I DIF AS MO NO RT H

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