De Sausa et al v. HSBC Bank U.S.A, N.A. et al
Filing
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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
-1-
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: (408) 317-1100
Facsimile: (408) 351-0105
margainlaw@hotmail.com
RICHARD C. J. WAHNG (SB# 225672)
LAW OFFICES OF RICHARD WAHNG
152 Anza Street, Suite 201
Fremont, CA 94539
Telephone: (510) 490-4447
Facsimile: (510) 344-5755
rwahng@gmail.com
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: 1(415) 856-7000
Facsimile: 1(415) 856-7100
jeffgrube@paulhastings.com
STEPHEN P. SONNENBERG (SB# 164881)
EMILY R. PIDOT (SB# 233241)
75 East 55th Street
New York, New York 10022
Telephone: 1(212) 318-6000
Facsimile: 1(212) 319-4090
stephensonnenberg@paulhastings.com
emilypidot@paulhastings.com
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
-2-
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
-5-
STIPULATION AND PROPOSED ORDER
TO CONTINUE INITIAL CASE
MANAGEMENT CONFERENCE
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