Strickland et al v. Wells Fargo Bank, N.A.

Filing 47

STIPULATION AND ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE HEARING DATE AND ADR DEADLINES. Case Management Conference set for 12/2/2010 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Signed by Judge Richard Seeborg on 9/22/10. (cl, COURT STAFF) (Filed on 9/23/2010)

*E-Filed 9/23/10*

1 2 3 4 5 6 7 8 9 10
1800 CENTURY PARK EAST, SECOND FLOOR, LOS ANGELES, CALIFORNIA 90067

Mónica Balderrama (SBN 196424) [e-mail] David Cheng (SBN 240926) [e-mail] Liana Beneli (SBN 256023) [e-mail] Initiative Legal Group APC 1800 Century Park East, 2nd Floor Los Angeles, California 90067 Telephone: [phone] Facsimile: [phone] Attorneys for All Plaintiffs UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA STEVEN STRICKLAND, et al. Plaintiffs, vs. WELLS FARGO BANK, N.A., a Delaware corporation; and DOES 1 through 10, inclusive, Defendants. Case No.: 3:10-cv-02812 RS Hon. Richard Seeborg STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE HEARING DATE AND ADR DEADLINES Complaint Filed: Trial Date: May 20, 2010 None set

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Case No. 3:10-cv-02812 RS
STIPULATION AND [PROPOSED] ORDER TO MOVE INITIAL CMC AND ADR DEADLINES

Initiative Legal Group APC

Action Removed: June 28, 2010

1 2 3 4 5 6 7 8 9 10
1800 CENTURY PARK EAST, SECOND FLOOR, LOS ANGELES, CALIFORNIA 90067

IT IS HEREBY STIPULATED BY COUNSEL FOR PLAINTIFFS STEVEN STRICKLAND, ET AL. AND DEFENDANT WELLS FARGO BANK, N.A. as follows: WHEREAS, the initial case management conference in this action has been set for October 14, 2010 ("CMC"). WHEREAS, pursuant to the order setting initial case management conference and ADR deadlines issued by the previous judge, Hon. Joseph Spero, both parties to the action must meet and confer re initial disclosures, early settlement, ADR process selection, discovery plan, as well as file ADR certification signed by parties and counsel, and either file stipulation to ADR process or notice of need for ADR phone conference by September 23, 2010 ("ADR Deadline"). 1 WHEREAS, pursuant to that same order both parties must also file a Rule 26(f) report, complete initial disclosures or state objection in Rule 26(f) report and file case management statement by October 7, 2010 ("Rule 26(f) Report Deadline"). WHEREAS, the motions to remand, to dismiss and to strike, and to stay this action are going to be heard on September 30, 2010, and both parties agree that the discussions regarding early settlement and ADR process as well as discovery planning are unlikely to be fruitful until these important motions are decided and the form of the pleadings is resolved. WHEREAS, both parties therefore would like to move the CMC to December 2, 2010, and move the ADR Deadline pursuant to ADR Local Rule 35 and the Rule 26(f) Report Deadline accordingly. The parties stipulate and propose that the ADR Deadline and the Rule 26(f) Report Deadline be moved by

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Initiative Legal Group APC

The dates are moved by six days according to the terms of Hon. Joseph Spero's order filed in this action on June 28, 2010.
Page 1 Case No. 3:10-cv-02812 RS

1

STIPULATION AND [PROPOSED] ORDER TO MOVE INITIAL CMC AND ADR DEADLINES

1 2 3 4 5 6 7 8 9 10
1800 CENTURY PARK EAST, SECOND FLOOR, LOS ANGELES, CALIFORNIA 90067

seven weeks to November 11, 2010, and November 23, 2010, respectively. IT IS HEREBY STIPULATED that Defendant Wells Fargo Bank, N.A. and Plaintiffs Strickland, et al. agree to continue the CMC date in this action to December 2, 2010, the ADR Deadline to November 11, 2010, and the Rule 26(f) Report Deadline to November 23, 2010. Dated: September 21, 2010 Respectfully submitted, Initiative Legal Group APC By: /s/ Liana Beneli Mónica Balderrama Liana Beneli David Cheng Attorneys for All Plaintiffs Littler Mendelson, P.C. By: /s/ Lindbergh Porter, Jr. Lindbergh Porter, Jr. Richard H. Rahm Alison S. Hightower Attorneys for Defendant

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
Page 2

Initiative Legal Group APC

Case No. 3:10-cv-02812 RS

STIPULATION AND [PROPOSED] ORDER TO MOVE INITIAL CMC AND ADR DEADLINES

1 2 3 4 5 6 7 8 9 10
1800 CENTURY PARK EAST, SECOND FLOOR, LOS ANGELES, CALIFORNIA 90067

ORDER IT IS HEREBY ORDERED that: 1. The Case Management Conference is hereby continued from

October 14, 2010 to December 2, 2010 at 10:00 a.m. 2. The parties' ADR deadline pursuant to ADR Local Rule 3-5 is

continued to November 11, 2010. 3. The parties' deadline to file a Rule 26(f) report, complete initial

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

disclosures or state objection in Rule 26(f) report and file a case management statement is continued to November 23, 2010.
9/22 Dated: _________, 2010

Initiative Legal Group APC

The Honorable Richard Seeborg United States District Court

Firmwide:97547362.1 051995.1023

Page 3

Case No. 3:10-cv-02812 RS

STIPULATION AND [PROPOSED] ORDER TO MOVE INITIAL CMC AND ADR DEADLINES