Brennan et al v. Wells Fargo Bank NA et al

Filing 22

STIPULATION AND ORDER RE: CASE MANAGEMENT: A Joint Updated Case Management Statement due by 2/7/2013. Further Case Management Conference set for 2/14/2013 at 10:30 AM in Courtroom C, 15th Floor, San Francisco. Signed by Magistrate Judge Laurel Beeler on 10/22/2012. (ls, COURT STAFF) (Filed on 10/22/2012)

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Michael F. Hardiman, State Bar# 104508
Wendy M. Schenk, State Bar# 177397
Hardiman & Carroll
450 Sansome Street, Suite 700
San Francisco, CA 94111
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
[e-mail]

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Stephen V. Wickersham, State Bar# 95585
Attorney at Law
7901 Stoneridge Drive, Suite 202
Pleasanton, California 94588
Tel: [phone]
Fax: [phone]
E-Mail: [e-mail]
Attorneys for Plaintiffs
Christine Brennan, Sarah Hsueh, and Bothaina Rasheed

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Allen Matkins Leek Gamble
Mallory & Natsis LLP
Baldwin J. Lee (Bar No. 187413)
Alexander Nestor (Bar No. 202795)
Three Embarcadero Center, 12th Floor
San Francisco, CA 94111-4074
Phone: [phone]
Fax: [phone]
E-Mail: [e-mail]
[e-mail]

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Attorneys for Defendants
Wells Fargo Bank, National Association and Ashoo Vaid

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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA - SAN FRANCISCO DIVISION
CHRISTINE BRENNAN, SARAH HSUEH,
and BOTHAINA RASHEED,

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Plaintiffs,
vs.

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CASE NO. 4:12-cv-00512 LB
Unlimited Jurisdiction

JOINT CASE MANAGEMENT
STATEMENT(UPDATED)AND
[PROPOSED] ORDER

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WELLS FARGO BANK NA, ASHOO VAID,)
and DOES 1 to 100, inclusive,
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Defendants.
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______________________________)

DATE:
TIME:
PLACE:
JUDGE:

October 24,2012
10:00 a.m.
Courtroom C, 15th Floor
Hon. Laurel Beeler

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JOINT CASE MANAGEMENT STATEMENT (UPDATED)
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Plaintiffs Christine Brennan, Sarah Hsueh, and Bothaina Rasheed (collectively

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"Plaintiffsn) and Defendants Wells Fargo Bank, National Association, and Ashoo Vaid

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(collectively "Defendants"), by and through their undersigned counsel of record, submit this

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updated Joint Case Management Statement in connection with the Case Management

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Conference set for October 24,2012, at 10:00 a.m.

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I.

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REQUEST TO REVISE SCHEDULING ORDER
Pursuant to the Court's June 26, 2012 Pretrial Order, the parties are required to complete

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ADR by October 25, 2012. The parties have agreed to mediation with Jeffrey Ross, but were

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not able to schedule a mediation date with Mr. Ross until February 6, 2013 due to his

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unavailability before that date and the need to complete certain discovery before the mediation.

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The non-expert discovery completion date currently is February 1, 2013. To enhance the

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opportunity for resolving this action at mediation, the parties would like to participate in

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mediation before the close of non-expert discovery, allowing the parties the opportunity to

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complete non-expert discovery after the mediation in the event mediation is not successful.

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The parties respectfully request that the Court modify the schedule and the following

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pretrial dates, as follows:

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1)

Schedule a Case Management Conference for 2/14/20 13 or a date more

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convenient for the Court. In the event the action is resolved at mediation on

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February 6, 2013, the parties shall advise the Court immediately and the Case

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Management Conference shall be vacated.

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2)

Extend the ADR completion date from 10125/2012 to 218/2013

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3)

Extend the non-expert discovery completion date from 21112013 to 313112013

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4)

Extend the last hearing date for dispositive motions from 411812013 to 513112013

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5)

Extend the expert disclosures from 411812013 to 51212013

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6)

Extend the rebuttal expert disclosures from 51312013 to 5117/2013; and

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III
III

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III

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JOINT CASE MANAGEMENT STATEMENT (UPDATED)
M:\S2400\S2400.208\pl003 joint erne 101812.doc

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Extend the expert discovery completion date from 6/3/2013 to 6/17/2013.

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,.,

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HARDIMAN & CARROLL

DATED:

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By

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Attorneys for Plaintiffs
CHRISTINE BRENNAN, SARAH HSUEH,
and BOTHAINA RASHEED

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DATED:

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ALLEN MATKINS LECK GAMBLE
MALLORY & NATSIS LLP

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By

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BALDWIN J. LEE
ALEXANDER NESTOR
Attorneys for Defendants
WELLS FARGO BANK, NATIONAL
ASSOCIATION and ASHOO YAID

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JOINT CASE MANAGEMENT STATEMENT (UPDATED)
M:\S2400\S2400.208\pl003 joint cmc 10 1812.doc

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[PROPOSED]ORDER
Pursuant to the request of the parties, and Good Cause appearing therefore, the Court
hereby orders that the following pretrial dates are scheduled and/or continued as follows:
at 10:30 a.m.

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1)

A Case Management Conference is scheduled for 2/14/2013. In the event this

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action is resolved at mediation on February 6, 2013, the parties shall advise the

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Court immediately and the Case Management Conference shall be vacated;

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2)

The ADR completion date is changed from 10/25/2012 to 2/7/2013;

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3)

The non-expert discovery completion date is changed from 2/112013 to
3/31/2013;

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4)

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The last hearing date for dispositive motions is changed from 4/18/2013 to
5/31/2013;

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5)

Expert disclosures are changed from 4/18/2013 to 5/12/2013;

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6)

Rebuttal expert disclosures are changed from 5/3/2013 to 5117/2013; and

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7)

The expert discovery completion date is changed from 6/3/2013 to 6117/2013.

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IT IS SO ORDERED.
The Case Management Conference set for 10/24/2012 at 10:00 a.m. is VACATED.
A Joint Updated Case Management Conference Statement due 2/7/2013.

DATED:

October 22, 2012

By
HON. LAUREL BEELER
UNITED STATES MAGISTRATE JUDGE

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JOINT CASE MANAGEMENT STATEMENT (UPDATED)
M:\S2400\S2400.208\pl003 joint erne 10 1812.doe