Haidee Estrella v. Freedom Financial Network LLC et al

Filing 203

ORDER adjusting discovery deadlines (tf, COURT STAFF) (Filed on 6/22/2011)

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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 CERTAIN
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 CERTAIN EXPERT
DISCOVERY DEADLINES

CASE NO. CV-09-03156 SI

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WHEREAS, on May 4, 2011, the Court issued an order setting certain deadlines related
to expert discovery, a copy of which is attached hereto as Exhibit A;
WHEREAS, the parties subsequently, by letter agreement, agreed to extend the deadline
for plaintiffs’ expert designations to May 31, 2011;
WHEREAS, in light of scheduling issues, the parties have agreed to further modify the
cutoff and designation dates related to certain remaining expert discovery;

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WHEREAS, such modifications will not affect any other dates set by the Court;

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IT IS ACCORDINGLY STIPULATED, pursuant to Civil L.R. 6-1(b), 6-2(a), and 7-12

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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 certain

expert discovery, set per the Court’s Order of May 5, 2011, be further modified as follows:

ATTORNEYS AT LAW
SAN FRANCISCO

F ENWICK & W EST LLP

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(a) Defendants’ Designation of Experts will move to June 27, 2011;

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(c) Plaintiffs’ Expert Rebuttal will move to July 14, 2011;

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(d) Expert Discovery Cutoff will move to August 1, 2011.

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2.

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

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27, 2010 shall remain in place.

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Dated: June 17, 2011

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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

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Attorneys for Plaintiffs HAIDEE ESTRELLA and
ANGELICA ARITA

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Dated: June 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

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STIPULATION AND [PROPOSED] ORDER
MODIFYING CERTAIN EXPERT
DISCOVERY DEADLINES

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CASE NO. CV-09-03156 SI

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Dated: June 17, 2011

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SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP

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By: /s/
Allen Ruby

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Attorneys for Defendants
BRADFORD STROH and ANDREW HOUSSER

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Dated: June 17, 2011

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By: /s/
Richard W. Epstein

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Attorneys for Defendants GLOBAL CLIENT
SOLUTIONS, LLC and ROCKY MOUNTAIN BANK &
TRUST

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ATTORNEYS AT LAW
SAN FRANCISCO

F ENWICK & W EST LLP

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GREENSPOON MARDER, P.A.

Pursuant to General Order No. 45 Section X(B), all of the signatories concur in the filing of this
stipulation.
Dated: June 17, 2011

FENWICK & WEST LLP
By: /s/ Jennifer C. Bretan
Jennifer C. Bretan

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STIPULATION AND [PROPOSED] ORDER
MODIFYING CERTAIN EXPERT
DISCOVERY DEADLINES

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CASE NO. CV-09-03156 SI

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[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 certain

expert discovery, set per the Court’s Order of May 4, 2011, shall be modified as follows:

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(a) The deadline for Defendants’ Designation of Experts is June 27, 2011;

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(b) The deadline for Plaintiffs’ Expert Rebuttal is July 14, 2011;

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(c) Expert Discovery Cutoff is August 1, 2011.
2.

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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:

6/21/11
Hon. Susan Illston
United States District Court Judge

ATTORNEYS AT LAW
SAN FRANCISCO

F ENWICK & W EST LLP

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STIPULATION AND [PROPOSED] ORDER
MODIFYING CERTAIN EXPERT
DISCOVERY DEADLINES

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CASE NO. CV-09-03156 SI

Exhibit A

Case3:09-cv-03156-SI Document196

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

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Filed05/05/11 Page4 of 8

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