Haidee Estrella v. Freedom Financial Network LLC et al

Filing 196

ORDER re: Expert Deadlines (tf, COURT STAFF) (Filed on 5/5/2011)

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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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ATTORNEYS AT LAW
SAN FRANCISCO

F ENWICK & W EST LLP

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NORTHERN DISTRICT OF CALIFORNIA
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,

Case No. CV-09-03156 SI
STIPULATION AND [PROPOSED]
ORDER MODIFYING EXPERT
DISCOVERY DEADLINES

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.

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STIPULATION AND [PROPOSED] ORDER
MODIFYING EXPERT DISCOVERY
DEADLINES

CASE NO. CV-09-03156 SI

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

discovery, set per the Court’s Order of March 18, 2011, shall be modified as follows:

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(a) Plaintiffs’ Designation of Experts is May 23, 2011;

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(b) Defendants’ Designation of Experts is June 13, 2011;

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(c) Plaintiffs’ Expert Rebuttal is June 30, 2011;

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(d) Expert Discovery Cutoff is July 18, 2011.

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2.

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All subsequent dates set pursuant to the Court’s Pretrial Preparation Order of

October 27, 2010 shall remain in place.

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ATTORNEYS AT LAW
SAN FRANCISCO

F ENWICK & W EST LLP

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Dated:

5/4/11
Hon. Susan Illston
United States District Court Judge

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STIPULATION AND [PROPOSED] ORDER
MODIFYING EXPERT DISCOVERY
DEADLINES

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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
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HAIDEE ESTRELLA,
Plaintiff,

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No. C 09-03156 SI
PRETRIAL PREPARATION ORDER

v.
FREEDOM FINANCIAL,
Defendant.

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/

United States District Court
For the Northern District of California

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It is hereby ORDERED pursuant to F.R.C.P. and the Local Rules of this Court:

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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.

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DESIGNATION OF EXPERTS: pltf. 5/6/11, deft. 5/27/11; REBUTTAL: 6/13/11.
Parties SHALL conform to Rule 26(a)(2).

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EXPERT DISCOVERY CUTOFF is June 30, 2011.

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DISPOSITIVE MOTIONS SHALL be filed by July 22, 2011;

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Opp. Due August 5, 2011; Reply Due August 12, 2011;

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and set for hearing no later than August 26, 2011 at 9:00 AM.

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PRETRIAL CONFERENCE DATE: September 27, 2011 at 3:30 PM.

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JURY TRIAL DATE: October 11, 2011 at 8:30 AM.,
Courtroom 10, 19th floor.

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TRIAL LENGTH is estimated to be

days.

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

Exhibit B

Case3:09-cv-03156-SI Document191

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Filed03/21/11 Page6 of 6

[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS HEREBY ORDERED THAT:
1.

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Pursuant to Civil L.R. 6-2(b), the cutoff and designation dates related to non-

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expert and expert discovery, set per the Court’s Pretrial Preparation Order of October 27, 2010,

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shall be modified as follows:

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(a) Non-Expert Discovery Cutoff is May 7, 2011;

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(b) Plaintiffs’ Designation of Experts is May 13, 2011;

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(c) Defendants’ Designation of Experts is June 3, 2011;

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(d) Plaintiffs’ Expert Rebuttal is June 20, 2011;

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(e) Expert Discovery Cutoff is July 7, 2011.

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2.

ATTORNEYS AT LAW
SAN FRANCISCO

F ENWICK & W EST LLP

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All other dates set pursuant to the Court’s Pretrial Preparation Order of October

27, 2010 shall remain in place.

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Dated:

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

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25455/00403/SF/5332433.2

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[PROPOSED] ORDER MODIFYING
CERTAIN DISCOVERY DEADLINES

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CASE NO. CV-09-03156 SI