Ubaldi v. SLM Corporation

Filing 118

STIPULATION AND MODIFIED ORDER re 115 STIPULATION re 113 MOTION to Compel Responses to Request for Production of Documents Nos. 39-55 filed by Sallie Mae, Inc., SLM Corporation, SLM PC Student Loan Trust 2004-A, Set/Re set Deadlines as to 115 STIPULATION WITH PROPOSED ORDER re 113 MOTION to Compel Responses to Request for Production of Documents Nos. 39-55 , 113 MOTION to Compel Responses to Request for Production of Documents Nos. 39-55. Responses due by 11/20/2012. Replies due by 12/4/2012. Motion Hearing set for 12/18/2012 09:00 AM in Courtroom E, 15th Floor, San Francisco before Magistrate Judge Elizabeth D. Laporte. Signed by Judge Elizabeth D Laporte on 11/14/2012. (knm, COURT STAFF) (Filed on 11/14/2012)

1
2
3
4
5
6
7
8
9

STROOCK & STROOCK & LAVAN LLP
JULIA B. STRICKLAND (State Bar No. 83013)
[e-mail]
LISA M. SIMONETTI (State Bar No. 165996)
[e-mail]
DAVID W. MOON (State Bar No. 197711)
[e-mail]
KRISTINA A. DEL VECCHIO (State Bar No. 283782)
[e-mail]
2029 Century Park East, 18th Floor
Los Angeles, California 90067-3086
Telephone: [phone]
Facsimile: 310-556-5959
[e-mail]
Attorneys for Defendants
SLM CORPORATION, SALLIE MAE, INC.
and SLM PC STUDENT LOAN TRUST 2004-A

10

UNITED STATES DISTRICT COURT

11

NORTHERN DISTRICT OF CALIFORNIA

12
13
14
15
16
17
18
19
20
21

TINA M. UBALDI, on behalf of herself and all )
others similarly situated,
)
)
Plaintiff,
)
)
v.
)
)
SLM CORPORATION, d/b/a SALLIE MAE, )
INC., d/b/a/ SALLIE MAE SERVICING, a
)
Delaware corporation,
)
)
Defendant.
)
)
)
)
)
)

Case No. 3:11-cv-01320 EDL
STIPULATION AND [PROPOSED]
ORDER CONTINUING HEARING AND
BRIEFING SCHEDULE ON MOTION TO
COMPEL RESPONSES TO REQUESTS
FOR PRODUCTION OF DOCUMENTS
NOS. 39-55 AS MODIFIED
Action Filed: March 18, 2011
[Local Rule 6-1(b)]
[Declaration of Lisa M. Simonetti filed
concurrently]

22
23
24

WHEREAS, on October 30, 2012, plaintiff Tina M. Ubaldi (“Plaintiff”) filed a
Motion To Compel Responses To Requests For Production Of Documents Nos. 39-55 (“Motion”);

25
26
27

WHEREAS, the deadline for defendants SLM Corporation, Sallie Mae, Inc. and
SLM PC Student Loan Trust 2004-A (“Defendants”) to file their Opposition to the Motion is
currently November 13, 2012;

28

-1STIPULATION AND [PROPOSED] ORDER
Case No. 3:11-cv-01320 EDL
LA 51599512

1

WHEREAS, Plaintiff’s Reply to the Motion is currently due on November 20, 2012;

2

WHEREAS, the hearing on the Motion is currently scheduled for December 4,

3

2012;

4

WHEREAS, Defendants’ counsel will be in arbitration on December 4, 2012 on

5

another matter, and the parties have agreed to continue the hearing on the Motion to Compel and to

6

adjust the briefing schedule accordingly;

7

WHEREAS, pursuant to Civil Local Rules 6-1(b) and 6-2, the parties may request

8

an order changing a deadline that involves papers required to be filed or lodged with the Court or

9

that would extend deadlines set forth in the Local Rules or Federal Rules; and

10

WHEREAS, this Stipulation is made in good faith and not for purposes of delay.

11

IT IS HEREBY STIPULATED by and between the parties, through their respective

12

counsel of record, as follows:

13
14

(a)

continued from November 13, 2012 to November 20, 2012;

15
16

The date by which Defendants must file their Opposition to the Motion is

(b)

The date by which Plaintiff must file her Reply is continued from November

20, 2012 to December 4, 2012;

17

///

18

///

19

///

20

///

21

///

22

///

23

///

24

///

25

///

26

///

27

///

28

-2STIPULATION AND [PROPOSED] ORDER
Case No. 3:11-cv-01320 EDL
LA 51599512

1
2

(c)
The hearing on the Motion is continued from December 4, 2012 to
18
December 11, 2012 at 9:00 a.m. in Courtroom E.

3
4

Dated: November 9, 2012

STROOCK & STROOCK & LAVAN LLP
JULIA B. STRICKLAND
LISA M. SIMONETTI
DAVID W. MOON
KRISTINA A. DEL VECCHIO

5
6

By: /s/ Lisa M. Simonetti
Lisa M. Simonetti

7
8

Attorneys for Defendants
SLM CORPORATION, SALLIE MAE,
INC. and SLM PC STUDENT LOAN
TRUST 2004-A

9
10
11

Dated:

November 9, 2012

LAW OFFICES OF JANET LINDNER
SPIELBERG
JANET LINDNER SPIELBERG

12
13

By: /s/ Janet L. Spielberg
Janet Lindner Spielberg

14

Attorneys for Plaintiff
TINA M. UBALDI

15
16
17
18
19

[PROPOSED] ORDER
PURSUANT TO THE STIPULATION, IT IS SO ORDERED.AS MODIFIED.

20
21

November 14, 2012
Dated: ________________________

22

________________________________________
The Honorable Elizabeth D. Laporte

23
24
25
26
27
28

-3STIPULATION AND [PROPOSED] ORDER
Case No. 3:11-cv-01320 EDL
LA 51599512

CERTIFICATE OF SERVICE

1
2
3
4

I hereby certify that, on NOVEMBER 9, 2012, copies of the foregoing STIPULATION
AND [PROPOSED] ORDER CONTINUING HEARING AND BRIEFING SCHEDULE ON
MOTION TO COMPEL RESPONSES TO REQUESTS FOR PRODUCTION OF

5
6

DOCUMENTS NOS. 39-55 were filed electronically and served by U.S. Mail on anyone unable to

7

accept electronic filing. Notice of this filing will be sent by e-mail to all parties by operation of the

8

court’s electronic filing system or by facsimile to anyone unable to accept electronic filing as

9

indicated on the Notice of Electronic Filing. Parties may access this filing through the court’s

10

EM/ECF System.

11
12

By:

13

/s/ Lisa M. Simonetti
Lisa M. Simonetti

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

-4STIPULATION AND [PROPOSED] ORDER
Case No. 3:11-cv-01320 EDL
LA 51599512