Bradshaw et al v. SLM Corporation et al

Filing 13

ORDER GRANTING 12 Stipulation to Extend Time to Respond to Plaintiffs' Complaint and Continue the Initial Case Management Conference. Case Management Statement due by 4/12/2013. Case Management Conference set for 4/19/2013 01:30 PM in Courtroom 11, 19th Floor, San Francisco. Signed by Judge Jeffrey S. White on February 6, 2013. (jswlc3, COURT STAFF) (Filed on 2/6/2013)

Case3:12-cv-06376-JSW Document12 Filed02/06/13 Page1 of 4

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STROOCK & STROOCK & LAVAN LLP
JULIA B. STRICKLAND (State Bar No. 083013)
LISA M. SIMONETTI (State Bar No. 165996)
KRISTINA A. DEL VECCHIO
2029 Century Park East
Los Angeles, CA 90067-3086
Telephone: [phone]
Facsimile: 310-556-5959
Email:
[e-mail]

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Attorneys for Defendants
SLM CORPORATION and SALLIE MAE, INC.
UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ANDREW BRADSHAW, TANIF
STEPHENSON, ADAM CORRIVEAU, and
JESELL GONZALEZ, on behlaf of themselves
and similarly situated individuals,
Plaintiff,
v.
SLM CORPORATION, a Delaware
corporation; and SALLIE MAE, INC., a
Delaware corporation,
Defendants.

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Case No. CV-12-6376-JSW
[Assigned to the Hon. Jeffrey S. White]
STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME TO
RESPOND TO PLAINTIFFS'
COMPLAINT AND CONTINUE THE
INITIAL CASE MANAGEMENT
CONFERENCE
Action Filed: December 17, 2012
[Local Rule 6-1(b)]
[Declaration of Lisa M. Simonetti filed
concurrently]

WHEREAS, plaintiffs Andrew Bradshaw, Tanif Stephenson, Adam Corriveau and Jesell

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Gonzalez (“Plaintiffs”) filed their Class Action Complaint for Equitable, Declaratory and

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Injunctive Relief and Damages For (1) Aiding and Abetting Fraud, (2) Mistake of Fact, (3) Unjust

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Enrichment, (4) Violations of the California Unfair Competition Law, and (5) Violations of the

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Oklahoma Consumer Protection Act (“Complaint”) on December 17, 2012;

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Case No. CV-12-6376-JSW
LA 51621002

Case3:12-cv-06376-JSW Document12 Filed02/06/13 Page2 of 4

WHEREAS, on or about January 16, 2013, the Complaint was served on defendants SLM

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Corporation and Sallie Mae, Inc. (“Defendants”);
WHEREAS, Plaintiffs filed their First Amended Class Action Complaint (“FAC”) on

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February 4, 2013;
WHEREAS, on or about February 4, 2013, counsel for Defendants agreed to accept service

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of the FAC on behalf of Defendants;

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WHEREAS, Defendants’ response to the FAC is due on February 25, 2013;

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WHEREAS, Plaintiffs have agreed to grant Defendants an extension of time to respond to
the FAC up to and including March 22, 2013;
WHEREAS, the Court has set the initial Case Management Conference for March 22, 2013

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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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at 1:30 p.m. (Dkt. No. 8), which is the same date that that Defendants’ response will be due in

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accordance with the parties’ agreement;

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WHEREAS, pursuant to Civil Local Rules 6-1(b) and 6-2, the parties may request an order

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changing a deadline that would extend deadlines set forth in the Local Rules or Federal Rules; and
WHEREAS, this Stipulation is made in good faith and not for purposes of delay.

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[Stipulation Continued On Next Page]

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-1Case No. CV-12-6376-JSW
LA 51621002

Case3:12-cv-06376-JSW Document12 Filed02/06/13 Page3 of 4

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IT IS HEREBY STIPULATED by and between the parties, through their respective counsel
of record, as follows:
(a)

The date by which Defendants must respond to Plaintiffs’ FAC is continued from

February 25, 2013 to March 22, 2013;
(b)

The date of the initial Case Management Conference is continued from March 22,

2013 to April 19, 2013 at 1:30 p.m.

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Dated: February 6, 2013

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2029 Century Park East
Los Angeles, California 90067-3086

STROOCK & STROOCK & LAVAN LLP

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By:

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Attorneys for Defendants
SLM CORPORATION and SALLIE MAE,
INC.

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/s/ Lisa M. Simonetti
Lisa M. Simonetti

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STROOCK & STROOCK & LAVAN LLP
JULIA B. STRICKLAND
LISA M. SIMONETTI
KRISTINA A. DEL VECCHIO

Dated: February 6, 2013

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WOLF LEGAL, P.C.
ADAM B. WOLF
TRACEY DEMMON BERGER
By:

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_

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/s/ Adam B. Wolf
Adam B. Wolf
Attorneys for Plaintiffs
ANDREW BRADSHAW, TANIF
STEPHENSON, ADAM CORRIVEAU,
and JESELL GONZALEZ

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[PROPOSED] ORDER

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PURSUANT TO THE STIPULATION, IT IS SO ORDERED.

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February 6, 2013
Dated: ________________________

________________________________________
The Honorable Jeffrey S. White

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-2Case No. CV-12-6376-JSW
LA 51621002