Wolin v. Wells Fargo Bank, National Association et al

Filing 23

STIPULATION AND ORDER TO CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND CORRESPONDING DEADLINES. The case management conference is continued to December 14, 2012. Signed by Judge Maxine M. Chesney on November 20, 2012. (mmclc2, COURT STAFF) (Filed on 11/20/2012)

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Counsel listed on following page.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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WILLIAM WOLIN, individually, and on
behalf of other members of the general
public similarly situated, and as aggrieved
employees pursuant to the Private
Attorneys General Act (“PAGA”),

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Plaintiff,

MMC
CASE NO. CV 12 4509 EDL
STIPULATION AND [PROPOSED]
ORDER TO CONTINUE INITIAL CASE
MANAGEMENT CONFERENCE AND
CORRESPONDING DEADLINES

v.
WELLS FARGO BANK, NATIONAL
ASSOCIATION, a national association;
WELLS FARGO & COMPANY, a
Delaware corporation; and DOES 1
through 10, inclusive,
Defendants.

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STIPULATION TO CONTINUE INITIAL
CASE MANAGEMENT CONFERENCE;
CASE NO. 12 4509

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MALCOLM A. HEINICKE (SBN 194174)
[e-mail]
MARI OVERBECK (SBN 261707)
[e-mail]
MUNGER, TOLLES & OLSON LLP
560 Mission Street
Twenty-Seventh Floor
San Francisco, CA 94105-2907
Telephone: [phone]
Facsimile:
[phone]

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TERRY E. SANCHEZ (SBN 101318)
[e-mail]
MUNGER, TOLLES & OLSON LLP
355 South Grand Avenue
Thirty-Fifth Floor
Los Angeles, CA 90071-1560
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Defendants
WELLS FARGO BANK, NATIONAL
ASSOCIATION; WELLS FARGO & COMPANY
MARK YABLONOVICH (SBN 186670)
[e-mail]
NEDA ROSHANIAN (SBN 225337)
[e-mail]
LAW OFFICES OF MARK YABLONOVICH
1875 Century Park East, Suite 700
Los Angeles, CA 90067-2508
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Plaintiff
WILLIAM WOLIN

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STIPULATION TO CONTINUE INITIAL
CASE MANAGEMENT CONFERENCE;
CASE NO. 12 4509

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Subject to the approval of the Court, the parties, by and through their undersigned

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counsel, hereby submit this Stipulation and [Proposed] Order to Continue Initial Case

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Management Conference and Corresponding Deadlines.
STIPULATION

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WHEREAS, the Initial Case Management Conference in this action is currently

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set for November 30, 2012 at 10:00 a.m., with the deadline for filing a Case Management Report

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set for November 23, 2012;
WHEREAS, soon after this action was first filed and while the matter was still

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assigned to United States Magistrate Judge Elizabeth Laporte (and before this matter was

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assigned to this Court), Defendants informed Plaintiff of their position that the case had been filed

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in the wrong district and requested that Plaintiff stipulate to a transfer of the matter;
WHEREAS, the parties in this action are in ongoing discussions to determine

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whether Plaintiff will stipulate to transfer this action to the United States District Court for the

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Central District of California, and Plaintiff has requested certain information, and the parties

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require additional time to complete these discussions;
WHEREAS, the parties’ request to extend the date of the Initial Case

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Management and its corresponding deadlines will make the best use of party and judicial

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resources;
WHEREAS, the parties have not previously sought to modify or extend any

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deadlines in this action, and the requested modification will have no effect on any other scheduled

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dates.

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NOW THEREFORE IT IS HEREBY STIPULATED AND AGREED, by and

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between the undersigned counsel for all parties that, subject to the approval of the Court, the Case

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Management Conference currently scheduled in this matter for November 30, 2012 shall be taken

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off calendar and continued to December 14, 2012 at 10:30 a.m., or such other date and time

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thereafter as the Court shall order, and all corresponding deadlines shall be continued in

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accordance with Civil Local Rule 16-9.

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STIPULATION TO CONTINUE INITIAL
CASE MANAGEMENT CONFERENCE;
CASE NO. 12 4509

IT IS SO STIPULATED.

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DATED: November 19, 2012

Munger, Tolles & Olson LLP

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By: /s/ Malcolm A. Heinicke
Malcolm A. Heinicke
Attorneys for Defendants
WELLS FARGO BANK, NATIONAL
ASSOCIATION; WELLS FARGO &
COMPANY

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DATED: November 19, 2012

Law Offices of Mark Yablonovich

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By: /s/ Mark Yablonovich
Mark Yablonovich
Attorneys for Plaintiff
WILLIAM WOLIN

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Filer’s Attestation

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I, Malcolm A. Heinicke, am the ECF user whose identification and password are

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being used to file this STIPULATION AND [PROPOSED] ORDER TO CONTINUE INITIAL
CASE MANAGEMENT CONFERENCE AND CORRESPONDING DEADLINES. In
compliance with Civil Local Rule 5-1(i)(3), I hereby attest that Mark Yablonovich concurs in this
filing.

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STIPULATION TO CONTINUE INITIAL
CASE MANAGEMENT CONFERENCE;
CASE NO. 12 4509

[PROPOSED] ORDER

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Having read the considered the Stipulation filed by the parties, and good cause appearing

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therefore, IT IS HEREBY ORDERED that the parties’ Case Management Conference is

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continued to December___, 2012 at 10:30 a.m., and all corresponding dates are hereby continued

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in accordance with Civil Local Rule 16-9(a).

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IT IS SO ORDERED.

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November 20
DATED: __________________, 2012

_________________________
Hon. Maxine M. Chesney
United States District Court Judge

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STIPULATION TO CONTINUE INITIAL
CASE MANAGEMENT CONFERENCE;
CASE NO. 12 4509