De Sausa et al v. HSBC Bank U.S.A, N.A. et al

Filing 22

STIPULATION AND ORDER to Continue the Initial Case Management Conference Pending Private Mediation. Case Management Statement due by 11/25/2013. Initial Case Management Conference set for 12/2/2013 01:30 PM in Courtroom 12, 19th Floor, San Francisco. Signed by Judge Thelton E. Henderson on 08/19/2013. (tmi, COURT STAFF) (Filed on 8/19/2013)

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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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FERNANDO DE SAUSA and JESSICA
SHUM on behalf of themselves, in the interest
of the general public and as a Private Attorney
General,

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STIPULATION AND [PROPOSED]
ORDER TO CONTINUE THE INITIAL
CASE MANAGEMENT CONFERENCE
HEARING PENDING PRIVATE
MEDIATION

Plaintiffs,

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CASE NO. CV12-05081

vs.
HSBC BANK U.S.A., N.A.; HSBC USA,
INC.; and HSBC NORTH AMERICA
HOLDINGS, INC.,
Defendants.

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Case No. CV12-05081

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STIPULATION AND PROPOSED ORDERTO
CONTINUE INITIAL CASE MANAGEMENT
CONFERENCE

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TOMAS E. MARGAIN (SB# 193555)
CASA LEGAL
84 W. Santa Clara St., Ste. 790
San Jose, CA 95113
Telephone: [phone]
Facsimile: [phone]
[e-mail]
RICHARD C. J. WAHNG (SB# 225672)
LAW OFFICES OF RICHARD WAHNG
152 Anza Street, Suite 201
Fremont, CA 94539
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Plaintiffs
FERNANDO DE SAUSA and JESSICA SHUM
E. JEFFREY GRUBE (SB# 167324)
PAUL HASTINGS LLP
55 Second Street, 24th Floor
San Francisco, California 94105-3441
Telephone: [phone]
Facsimile: 1(415) 856-7100
[e-mail]
STEPHEN P. SONNENBERG (SB# 164881)
EMILY R. PIDOT (SB# 233241)
75 East 55th Street
New York, New York 10022
Telephone: [phone]
Facsimile: 1(212) 319-4090
[e-mail]
[e-mail]
Attorneys for Defendants
HSBC BANK U.S.A., N.A., HSBC USA, INC., and HSBC
NORTH AMERICA HOLDINGS, INC.

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Case No. CV12-05081

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STIPULATION AND PROPOSED ORDER
TO STAY PROCEEDINGS AND TO
CONTINUE INITIAL CASE MANAGEMENT

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The parties to this litigation, by and through their respective attorneys of record, hereby
submit this stipulation and [proposed] order to continue the Initial Case Management Conference
currently scheduled to be held on August 26, 2013, at 1:30 p.m., to a date to be scheduled at the
Court’s convenience no earlier than December 2, 2013 for the reasons set forth below.
WHEREAS, the Initial Case Management Conference in this action currently is scheduled
for August 26, 2013, at 1:30 p.m.;
WHEREAS, the parties have agreed to pursue settlement discussions through private
mediation, which is anticipated to be held in October 2013. The parties intend to engage in an
informal exchange of confidential documents and data prior to mediation for purposes of
facilitating settlement negotiations;
WHEREAS, the parties wish to exhaust attempts to mediate the case before addressing
fact and expert discovery cut offs and a trial date and, as such, wish to postpone the initial Case
Management Conference until after the mediation session.
Accordingly, the parties to this matter, by and through their respective attorneys of
record, hereby stipulate to and jointly request that the Court continue for ninety (90) days , the
Initial Case Management Conference be continued to December 2, 2013, at 1:30 p.m. or such
other date as is convenient for the Court.
SO STIPULATED.

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Case No. CV12-05081

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STIPULATION AND PROPOSED ORDER
TO STAY PROCEEDINGS AND TO
CONTINUE INITIAL CASE MANAGEMENT

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DATED: August 19, 2013

TOMAS E. MARGAIN
CASA LEGAL

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By: /s/ Tomas E. Margain
TOMAS E. MARGAIN
Attorneys for Plaintiffs
FERNANDO DE SAUSA and JESSICA SHUM

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DATED: August 16, 2013

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E. JEFFREY GRUBE
PAUL HASTINGS LLP
By: /s/ E. JEFFREY GRUBE
E. JEFFREY GRUBE

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Attorneys for Defendants
HSBC BANK U.S.A., N.A., HSBC USA, INC., and
HSBC NORTH AMERICA HOLDINGS, INC.

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Case No. CV12-05081

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STIPULATION AND PROPOSED ORDER
TO STAY PROCEEDINGS AND TO
CONTINUE INITIAL CASE MANAGEMENT

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[Proposed] Order
Good cause appearing, the initial Case Management conference scheduled for August 26,
2013 shall be continued to December 2, 2013, at 1:30 p.m. The Initial Case Management
Conference Statement shall be filed on or before November 25, 2013.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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________________________________________
THELTON E. HENDERSON
UNITED STATES DISTRICT JUDGE
UNIT
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Dated: 08/19/2013
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Case No. CV12-05081

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STIPULATION AND PROPOSED ORDER
TO STAY PROCEEDINGS AND TO
CONTINUE INITIAL CASE MANAGEMENT