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

Filing 24

STIPULATION AND ORDER to Continue Case Management Conference. Case Management Statement due by 2/24/2014. Initial Case Management Conference set for 3/3/2014 01:30 PM in Courtroom 12, 19th Floor, San Francisco. Signed by Judge Thelton E. Henderson on 11/21/2013. (tmi, COURT STAFF) (Filed on 11/22/2013)

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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
PENDING PRIVATE MEDIATION

Plaintiffs,

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CASE NO. CV12-05081-TEH

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 ORDER
TO CONTINUE INITIAL CASE
MANAGEMENT CONFERENCE

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TOMAS E. MARGAIN (SB# 193555)
JUSTICE AT WORK LAW GROUP
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 CONTINUE INITIAL CASE
MANAGEMENT CONFERENCE

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The parties to this litigation, by and through their respective attorneys of record, hereby

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submit this stipulation and [proposed] order to continue the Initial Case Management Conference

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which is currently scheduled to be held on December 2, 2013, at 1:30 p.m., to a date to be

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scheduled at the Court’s convenience no earlier than March 3, 2014 for the reasons set forth

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below.

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WHEREAS, the Initial Case Management Conference in this action currently is scheduled
for December 2, 2013, at 1:30 p.m.;
WHEREAS, the parties have agreed to hold a mediation at JAMS before the Honorable
William J. Cahill on January 24, 2014. The parties already have discussed the types of data and

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documents to exchange confidentially and informally prior to mediation for purposes of

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facilitating settlement negotiations;

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WHEREAS, the parties have agreed to mediate, as part of the same mediation described

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immediately above, the claims of another individual who is not a party to this lawsuit but for

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whom the undersigned have entered into a statute of limitations tolling agreement to facilitate

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mediation;

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WHEREAS, the parties wish to exhaust attempts to resolve this matter through mediation

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before addressing fact and expect discovery cutoffs and a trial date and, as such, wish to postpone

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the Initial Case Management Conference until after the mediation session.

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Accordingly, the parties to this matter, by and through their respective attorneys of record,

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hereby stipulate to and jointly request that the Initial Case Management Conference be continued

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to March 3, 2014, at 1:30 p.m. or such other date as is convenient for the Court.

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SO STIPULATED.

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Case No. CV12-05081

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STIPULATION AND PROPOSED ORDER
TO CONTINUE INITIAL CASE
MANAGEMENT CONFERENCE

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DATED: November 20, 2013

TOMAS E. MARGAIN
JUSTICE AT WORK LAW GROUP

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By:

/s/
TOMAS E. MARGAIN

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Attorneys for Plaintiffs
FERNANDO DE SAUSA and JESSICA SHUM

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DATED: November 20, 2013

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E. JEFFREY GRUBE
PAUL HASTINGS LLP
By:

/s/
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 CONTINUE INITIAL CASE
MANAGEMENT CONFERENCE

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[Proposed] Order

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Good cause appearing, the Initial Case Management Conference scheduled for December

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2, 2013 shall be continued to March 3, 2014, at 1:30 p.m. The Initial Case Management

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Conference Statement shall be filed on or before February 24, 2014.

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PURSUANT TO STIPULATION, IT IS SO ORDERED.

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Dated:

11/21/2013

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________________________________________
THELTON E. HENDERSON
UNITED STATES DISTRICT JUDGE

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Case No. CV12-05081

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STIPULATION AND PROPOSED ORDER
TO CONTINUE INITIAL CASE
MANAGEMENT CONFERENCE