Haidee Estrella v. Freedom Financial Network LLC et al

Filing 136

ORDER CONTINUING CMC TO 8/6/10 @ 3:00 P.M. (tf, COURT STAFF) (Filed on 6/15/2010)

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FENWICK & W E S T LLP
ATTORNEYS AT LAW S A N FR A N C I S C O

KEVIN P. MUCK (CSB NO. 120918) [e-mail] CHRISTOPHER J. STESKAL (CSB NO. 212297) [e-mail] JENNIFER BRETAN (CSB NO. 233475) [e-mail] MARIE C. BAFUS (CSB NO. 258417) [e-mail] FENWICK & WEST LLP 555 California Street, 12th Floor San Francisco, CA 94104 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants Freedom Financial Network, LLC, Freedom Debt Relief, Inc. and Freedom Debt Relief, LLC

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION HAIDEE ESTRELLA, an individual, and ANGELICA ARITA, an individual, on behalf of themselves and all others similarly situated, and on behalf of the general public, Plaintiffs, v. FREEDOM FINANCIAL NETWORK, LLC, et al., Defendants. Case No. CV-09-03156 SI STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE

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STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE

CASE NO. CV-09-03156 SI

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FENWICK & W E S T LLP
ATTORNEYS AT LAW S A N FR A N C I S C O

WHEREAS, on June 2, 2010, in conjunction with the Court's Order on class certification, the Court continued the Case Management Conference scheduled for June 3, 2010 in the above-captioned matter to June 25, 2010; WHEREAS, consistent with the April 30, 2010 letter previously filed with the Court, the June 25, 2010 date continues to present a conflict for counsel for defendants Freedom Debt Relief, LLC, Freedom Debt Relief, Inc., and Freedom Financial Network (collectively, the "Freedom Defendants"); WHEREAS, the parties have conferred and determined that the first date on which all counsel are available, in light of the aforementioned conflict and pending trial schedules, appears to be the afternoon of August 6, 2010; WHEREAS, the parties respectfully submit that it is therefore in the interest of judicial economy and efficiency to continue the June 25, 2010 Case Management Conference to August 6, 2010, a date which will allow the parties sufficient time to meet and confer regarding the submission of a Joint Case Management Statement following the Court's decision on class certification and to agree on a form of notice to absent class members; IT IS ACCORDINGLY STIPULATED, pursuant to Civil L.R. 7-12, by and between the undersigned counsel for the Parties that: 1. Pursuant to Civil L.R. 16-2, the Case Management Conference scheduled for June

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25, 2010 be vacated and rescheduled to August 6, 2010 at 3:00 p.m., or such other time as the Court shall determine to be appropriate; and 2. The associated Joint Case Management Statement deadline likewise be deferred to

July 30, 2010; and 3. The parties shall meet and confer concerning the manner, form and content of

notice to be provided to absent class members and submit a proposal concerning same to the Court in writing by July 30, 2010. /// /// ///
STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE

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CASE NO. CV-09-03156 SI

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FENWICK & W E S T LLP
ATTORNEYS AT LAW S A N FR A N C I S C O

Dated: June 7, 2010

CLARK & MARKHAM LLP LAW OFFICES OF BARRON E. RAMOS KERSHAW, CUTTER, & RATINOFF LLP CHARLES E. AMES, P.C. THE CROSLEY LAW FIRM, P.C. WEXLER WALLACE LLP By: /s/ Stuart C. Talley______________________ Stuart C. Talley Attorneys for Plaintiffs HAIDEE ESTRELLA and ANGELICA ARITA

Dated: June 7, 2010

FENWICK & WEST LLP By: /s/ Kevin P. Muck_____________________ Kevin P. Muck Attorneys for Defendants FREEDOM FINANCIAL NETWORK, LLC, FREEDOM DEBT RELIEF, INC. and FREEDOM DEBT RELIEF, LLC

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STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE

Dated: June 7, 2010

LAW OFFICES OF ALLEN RUBY By: /s/ Allen Ruby______________________ Allen Ruby Attorneys for Defendants BRADFORD STROH and ANDREW HOUSSER

Dated: June 7, 2010

GREENSPOON MARDER, P.A. By: /s/ Richard W. Epstein_________________ Richard W. Epstein Attorneys for Defendants GLOBAL CLIENT SOLUTIONS, LLC & ROCKY MOUNTAIN BANK & TRUST

Pursuant to General Order No. 45 Section X(B), all of the signatories concur in the filing of this stipulation. Dated: June 7, 2010 FENWICK & WEST LLP By: /s/ Jennifer C. Bretan Jennifer C. Bretan 3
CASE NO. CV-09-03156 SI

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FENWICK & W E S T LLP
ATTORNEYS AT LAW S A N FR A N C I S C O

[PROPOSED] ORDER IT IS HEREBY ORDERED THAT: 1. Pursuant to Civil L.R. 16-2, the Case Management Conference scheduled for June

25, 2010 be vacated and rescheduled to August 6, 2010 at 3:00 p.m., or such other time as the Court shall determine to be appropriate; and 2. The associated Joint Case Management Statement deadline likewise be deferred to

July 30, 2010; and 3. The parties shall meet and confer concerning the manner, form and content of

notice to be provided to absent class members and submit a proposal concerning same to the Court by July 30, 2010.

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Dated: Hon. Susan Illston United States District Court Judge

25455/00403/SF/5298511.2

STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE

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CASE NO. CV-09-03156 SI