Haidee Estrella v. Freedom Financial Network LLC et al

Filing 191

ORDER adjusting extending deadlines re 190 Stipulation. (tf, COURT STAFF) (Filed on 3/21/2011) Modified on 3/22/2011 (ys, COURT STAFF).

Haidee Estrella v. Freedom Financial Network LLC et al

Doc. 191

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F ENWICK & W EST LLP
ATTORNEYS AT LAW SAN FRANCISCO

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 a Delaware limited liability company; FREEDOM DEBT RELIEF, INC., a California corporation; FREEDOM DEBT RELIEF, LLC, a Delaware limited liability company; GLOBAL CLIENT SOLUTIONS, LLC; ROCKY MOUNTAIN BANK AND TRUST; ANDREW HOUSSER; AND BRADFORD STROH and DOES 1 through 100, Defendants. Case No. CV-09-03156 SI STIPULATION AND [PROPOSED] ORDER MODIFYING CERTAIN DISCOVERY DEADLINES UNDER PRETRIAL PREPARATION ORDER

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STIPULATION AND [PROPOSED] ORDER MODIFYING CERTAIN DISCOVERY DEADLINES

CASE NO. CV-09-03156 SI
Dockets.Justia.com

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F ENWICK & W EST LLP
ATTORNEYS AT LAW SAN FRANCISCO

WHEREAS, on October 27, 2010, the Court issued a Pretrial Preparation Order setting certain deadlines related to non-expert and expert discovery, and attached hereto as Exhibit A; WHEREAS, pursuant to that Order, the non-expert discovery cutoff was set for April 30, 2011; WHEREAS, the schedules of the parties and certain trial schedules of their counsel have rendered it highly difficult to complete non-expert discovery within the allotted time; WHEREAS, the parties respectfully submit that it is therefore in the interest of the parties to modify the cutoff and designation dates related to non-expert and expert discovery by seven calendar days in order to accommodate the schedules of the parties and their counsel; IT IS ACCORDINGLY STIPULATED, pursuant to Civil L.R. 6-1(b), 6-2(a), and 7-12 by and between the undersigned counsel for the Parties that: 1. Pursuant to Civil L.R. 6-2(a), the cutoff and designation dates related to non-expert

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and expert discovery, set per the Court's Pretrial Preparation Order of October 27, 2010, be modified as follows: (a) Non-Expert Discovery Cutoff will move from April 30, 2011 to May 7, 2011; (b) Plaintiffs' Designation of Experts will move from May 6, 2011 to May 13, 2011; (c) Defendants' Designation of Experts will move from May 27, 2011 to June 3, 2011; (d) Plaintiffs' Expert Rebuttal will move from June 13, 2001 to June 20, 2011; (e) Expert Discovery Cutoff will move from June 30, 2011 to July 7, 2011. 2. All other dates set pursuant to the Court's Pretrial Preparation Order of October

27, 2010 shall remain in place. Dated: March 17, 2011 KERSHAW, CUTTER, & RATINOFF LLP CLARK & MARKHAM LLP LAW OFFICES OF BARRON E. RAMOS CHARLES E. AMES, P.C. THE CROSLEY LAW FIRM, P.C. WEXLER WALLACE LLP By: /s/ Stuart C. Talley .

Attorneys for Plaintiffs HAIDEE ESTRELLA and ANGELICA ARITA
STIPULATION AND [PROPOSED] ORDER MODIFYING CERTAIN DISCOVERY DEADLINES

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CASE NO. CV-09-03156 SI

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Dated: March 17, 2011

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

Dated: March 17, 2011

LAW OFFICES OF ALLEN RUBY By: /s/ Allen Ruby .

Attorneys for Defendants BRADFORD STROH and ANDREW HOUSSER Dated: March 17, 2011 GREENSPOON MARDER, P.A. By: /s/ Richard W. Epstein .

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F ENWICK & W EST LLP
ATTORNEYS AT LAW SAN FRANCISCO

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STIPULATION AND [PROPOSED] ORDER MODIFYING CERTAIN DISCOVERY DEADLINES

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: March 17, 2011 FENWICK & WEST LLP By: /s/ Jennifer C. Bretan Jennifer C. Bretan

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CASE NO. CV-09-03156 SI

Exhibit A

Case3:09-cv-03156-SI Document147 Filed10/27/10 COURT of 1 IN THE UNITED STATES DISTRICT Page1 FOR THE NORTHERN DISTRICT OF CALIFORNIA 1 2 3 4 5 6 7 United States District Court For the Northern District of California 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 It is hereby ORDERED pursuant to F.R.C.P. and the Local Rules of this Court: FURTHER CASE MANAGEMENT: February 25, 2011 at 3:00 p.m. Counsel must file a joint case management statement seven days in advance of the conference. Case continued to 2/25/11 @ 9:00 a.m. for Cross Motions for Summary Adjudication (file 1/21/11, opposition 2/4/11, reply 2/11/11) DISCOVERY PLAN: Per F.R.Civ.P and Local Rules, subject to any provisions below. NON-EXPERT DISCOVERY CUTOFF is April 30, 2011. DESIGNATION OF EXPERTS: pltf. 5/6/11, deft. 5/27/11; REBUTTAL: 6/13/11. Parties SHALL conform to Rule 26(a)(2). EXPERT DISCOVERY CUTOFF is June 30, 2011. DISPOSITIVE MOTIONS SHALL be filed by July 22, 2011; Opp. Due August 5, 2011; Reply Due August 12, 2011; and set for hearing no later than August 26, 2011 at 9:00 AM. PRETRIAL CONFERENCE DATE: September 27, 2011 at 3:30 PM. JURY TRIAL DATE: October 11, 2011 at 8:30 AM., Courtroom 10, 19th floor. TRIAL LENGTH is estimated to be days. v. FREEDOM FINANCIAL, Defendant. / HAIDEE ESTRELLA, Plaintiff, No. C 09-03156 SI PRETRIAL PREPARATION ORDER

SPECIAL DISCOVERY AND PRETRIAL PROVISIONS: This case shall be referred to Magistrate Judge Spero for settlement purposes. The settlement conference shall occur between February 7 through the 18th, 2011. The pretrial conference SHALL be attended by trial counsel prepared to discuss all aspects of the case, including settlement. Parties SHALL conform to the attached instructions. Plaintiff is ORDERED to serve a copy of this order on any party subsequently joined in this action. Dated: SUSAN ILLSTON United States District Judge

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F ENWICK & W EST LLP
ATTORNEYS AT LAW SAN FRANCISCO

[PROPOSED] ORDER PURSUANT TO STIPULATION, IT IS HEREBY ORDERED THAT: 1. Pursuant to Civil L.R. 6-2(b), the cutoff and designation dates related to non-

expert and expert discovery, set per the Court's Pretrial Preparation Order of October 27, 2010, shall be modified as follows: (a) Non-Expert Discovery Cutoff is May 7, 2011; (b) Plaintiffs' Designation of Experts is May 13, 2011; (c) Defendants' Designation of Experts is June 3, 2011; (d) Plaintiffs' Expert Rebuttal is June 20, 2011; (e) Expert Discovery Cutoff is July 7, 2011. 2. All other dates set pursuant to the Court's Pretrial Preparation Order of October

27, 2010 shall remain in place.

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[PROPOSED] ORDER MODIFYING CERTAIN DISCOVERY DEADLINES
25455/00403/SF/5332433.2

Dated:

3/18/11 Hon. Susan Illston United States District Court Judge

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CASE NO. CV-09-03156 SI