Haidee Estrella v. Freedom Financial Network LLC et al

Filing 194

ORDER Further Case Management Conference set for 7/15/2011 03:00 PM. (tf, COURT STAFF) (Filed on 5/2/2011)

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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

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

ATTORNEYS AT LAW
SAN FRANCISCO

F ENWICK & W EST LLP

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SAN FRANCISCO DIVISION

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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,

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Plaintiffs,

Case No. CV-09-03156 SI
STIPULATION AND [PROPOSED]
ORDER CONTINUING CASE
MANAGEMENT CONFERENCE

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.

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STIPULATION AND [PROPOSED] ORDER
CONTINUING CASE MANAGEMENT
CONFERENCE

CASE NO. CV-09-03156 SI

WHEREAS, Plaintiffs Haidee Estrella and Angelica Arita (“Plaintiffs”) and Defendants

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Freedom Debt Relief, LLC, Freedom Debt Relief, Inc., Freedom Financial Network, LLC,

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Andrew Housser and Brad Stroh (collectively, the “Freedom Defendants”) have agreed to a

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further settlement conference with Magistrate Judge Joseph C. Spero set for April 27, 2011;
WHEREAS, Plaintiffs and Defendants Rocky Mountain Bank & Trust and Global Client

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Solutions have entered into a tentative settlement agreement with the Class and are still in the

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process of putting together the proposed agreement for submission to the Court;

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WHEREAS, the parties previously stipulated to an order continuing the original February

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25, 2011 Case Management Conference to May 6, 2011, in order to provide time for the Court to

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render its decision on the parties’ cross motions for summary judgment;
WHEREAS, on March 14, 2011, the Court issued an order denying the parties’ cross-

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ATTORNEYS AT LAW
SAN FRANCISCO

F ENWICK & W EST LLP

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motions;
WHEREAS, counsel for certain defendants now has a scheduling conflict on May 6,

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2011;
WHEREAS, the parties are in the process of completing fact discovery, which closes

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May 7, 2011, followed by expert discovery, which closes July 7, 2011;
WHEREAS, the parties respectfully submit that it is therefore in the interest of judicial

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economy and efficiency to continue the May 6, 2011 Case Management Conference to

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July 15, 2011, at which time the parties expect to have completed discovery in this matter;
IT IS ACCORDINGLY STIPULATED, pursuant to Civil L.R. 7-12, by and between

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the undersigned counsel for the Parties that:

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1.

Pursuant to Civil L.R. 16-2, the Case Management Conference scheduled for May

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6, 2011 be vacated and rescheduled to July 15, 2011 at 3:00 p.m., or such other time as the Court

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shall determine to be appropriate; and

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2.

The associated Joint Case Management Statement deadline shall likewise be

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deferred for submission consistent with Civil L.R. 16-10(d).

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STIPULATION AND [PROPOSED] ORDER
CONTINUING CASE MANAGEMENT
CONFERENCE

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CASE NO. CV-09-03156 SI

[PROPOSED] ORDER

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PURSUANT TO STIPULATION, IT IS HEREBY ORDERED THAT:
1.

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Pursuant to Civil L.R. 16-2, the Case Management Conference scheduled for May

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6, 2011 be vacated and rescheduled to July 15, 2011 at 3:00 p.m., or such other time as the Court

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shall determine to be appropriate; and
2.

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The associated Joint Case Management Statement deadline shall likewise be

deferred for submission consistent with Civil L.R. 16-10(d).

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5/2/11
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Dated:
Hon. Susan Illston
United States District Court Judge

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ATTORNEYS AT LAW
SAN FRANCISCO

F ENWICK & W EST LLP

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STIPULATION AND [PROPOSED] ORDER
CONTINUING CASE MANAGEMENT
CONFERENCE

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CASE NO. CV-09-03156 SI