Crago v. Charles Schwab & Co., Inc. et al

Filing 100

STIPULATION AND ORDER RE 99 TO CONTINUE CASE MANAGEMENT CONFERENCE AND EXTEND DEADLINE TO RESPOND TO SECOND AMENDED COMPLAINT. Initial Case Management Conference previously set for 12/14/2017 continued to 1/25/2018 at 10:00 AM in Courtroom 3, 17th Floor, San Francisco. Case Management Statement Due 1/18/2018. Signed by Judge Richard Seeborg on 12/7/17. (cl, COURT STAFF) (Filed on 12/7/2017)

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ARNOLD & PORTER KAYE SCHOLER LLP
GILBERT R. SEROTA (SBN 75305)
[e-mail]
JEE YOUNG YOU (SBN 241658)
[e-mail]
Three Embarcadero Center, 10th Floor
San Francisco, CA 94111-4024
Telephone: [phone]
Facsimile: [phone]
LOWELL HAKY (SBN 178526)
Vice President and Associate General Counsel
MAI KLAASSEN (SBN 209546)
Vice President and Associate General Counsel
CHARLES SCHWAB & CO., INC.
211 Main Street
San Francisco, CA 94105
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants CHARLES SCHWAB & CO.,
INC. and THE CHARLES SCHWAB CORPORATION

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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ROBERT CRAGO, Individually And On Behalf
Of All Others Similarly Situated,

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Case No. 3:16-cv-3938-RS
CLASS ACTION
ORDER

Plaintiff,

STIPULATION TO (1) CONTINUE CASE
MANAGEMENT CONFERENCE AND (2)
EXTEND DEADLINE TO RESPOND TO
SECOND AMENDED COMPLAINT

v.
CHARLES SCHWAB & CO., INC., and THE
CHARLES SCHWAB CORPORATION,
Defendants.

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Pursuant to Local Rule 6-2, Defendants Charles Schwab & Co., Inc. and The Charles
Schwab Corporation (“Defendants” or “Schwab”) and Lead Plaintiffs Robert Wolfson and Frank
Pino (“Lead Plaintiffs”; collectively the “Parties”), by and through their respective counsel, for
good cause, hereby stipulate as follows:
WHEREAS, on December 5, 2017, this Court issued an Order Denying Defendants’ Motion
to Dismiss the Second Amended Complaint (“Order,” ECF 98);
-1STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS

WHEREAS, the initial case management conference (“CMC”) is currently scheduled for

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December 14, 2017, at 10:00 a.m., and the CMC statement is due on December 7, 2017 (ECF 77);
WHEREAS, lead counsel for Schwab has been in arbitration this week, and is expected to

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be in arbitration through December 8, 2017, thus the parties are unable to meaningfully meet and
confer prior to the December 7, 2017 deadline to file the CMC statement;
WHEREAS, the Parties agree that additional time to confer regarding the case schedule,

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ADR processes, and the CMC statement is necessary in the interest of judicial efficiency,
administration and justice, as well as conservation of judicial and private resources;
WHEREAS, the current deadline for Defendants to respond to the Second Amended

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Complaint (“SAC”) is December 19, 2017;
WHEREAS, due to previously-scheduled deadlines and obligations, Defendants have

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requested and Plaintiffs have agreed to an additional 30 days for Defendants to respond to the SAC;
WHEREAS, the Parties have previously requested and were granted extensions of time to

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respond to the complaint and requested to continue the initial case management conference (ECF
23, 39, 76), and the changes requested herein will not alter the date of any deadlines already fixed
by Court order, as this Court has yet to schedule pre-trial and trial dates.
NOW, THEREFORE, IT IS STIPULATED BY AND AGREED AMONG THE PARTIES,

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SUBJECT TO APPROVAL BY THIS COURT, by these parties through their respective counsel of
record, as follows:
1. Schwab’s deadline to file its response to the Second Amended Complaint will be

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January 12, 2018;

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2. The initial Case Management Conference will be continued to January 25, 2018, or

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another date no earlier than January 25, 2018, as determined by this Court.

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-2STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS

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IT IS SO STIPULATED.

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Dated: December 7, 2017

ARNOLD & PORTER KAYE SCHOLER LLP

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By:

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/s/ Jee Young You
Gilbert R. Serota
Jee Young You
[e-mail]
[e-mail]
Three Embarcadero Center, 10th Floor
San Francisco, CA 94111-4024
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants

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Dated: December 7, 2017

GLANCY PRONGAY & MURRAY LLP

By: /s/ Joshua L. Crowell
Joshua L. Crowell (#295411)
1925 Century Park East, Suite 2100
Los Angeles, California 90067
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Co-Lead Counsel for Lead Plaintiffs and
the Class
BRAGAR EAGEL & SQUIRE, P.C.

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By:

/s/ David J. Stone
David J. Stone
885 Third Avenue, Suite 3040
New York, New York 10022
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Co-Lead Counsel for Lead Plaintiffs and
the Class

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-3STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS

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ATTESTATION

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I, Jee Young You, am the ECF User whose identification and password are being used to
file this STIPULATION TO (1) CONTINUE CASE MANAGEMENT CONFERENCE AND
(2) EXTEND DEADLINE TO RESPOND TO SECOND AMENDED COMPLAINT.

In

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compliance with Local Rule 5-1(i)(3), I hereby attest that Counsel for Defendants concur in this

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filing.

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DATED: December 7, 2017

/s/ Jee Young You
JEE YOUNG YOU

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STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS

[PROPOSED] ORDER

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NOW, THEREFORE, IT IS STIPULATED BY AND AGREED AMONG THE PARTIES:
1. Schwab’s deadline to file its response to the Second Amended Complaint will be
January 12, 2018;
2. The initial Case Management Conference will be continued to January 25, 2018, or
another date no earlier than January 25, 2018, as determined by this Court.
IT IS SO ORDERED.

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DATED: 12/7/17

Hon. Richard Seeborg
U.S. District Court Judge

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STIPULATION AND [PROPOSED] ORDER
Case No. 16-cv-3938-RS