Villegas v. J.P. Morgan Chase & Co. et al

Filing 99

STIPULATION AND CASE MANAGEMENT SCHEDULING ORDER: Discovery due by 1/7/2011. Jury Trial set for 4/11/2011 08:30 AM. Motions due by 2/15/2011. Pretrial Conference set for 4/5/2011 01:00 PM.. Signed by Judge ARMSTRONG on 3/8/10. (lrc, COURT STAFF) (Filed on 3/9/2010)

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1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 CARRIE A. GONELL, State Bar No. 257163 MORGAN, LEWIS & BOCKIUS LLP 5 Park Plaza, Suite 1750 Irvine, CA 92614 Tel: 949.399.7000 Fax: 949.399.7001 Email: cgonell@morganlewis.com LAUREN S. KIM, State Bar No. 210572 MORGAN, LEWIS & BOCKIUS LLP 2 Palo Alto Square 3000 El Camino Real, Suite 700 Palo Alto, CA 94306-2122 Tel: 650.843.4000 Fax: 650.843.4001 Email: lkim@morganlewis.com Attorney for Defendants JPMORGAN CHASE & CO., JPMORGAN CHASE BANK, N.A., and CHASE BANK USA, N.A. PETER M. HART, State Bar No. 198691 LAW OFFICES OF PETER M. HART 13952 Bora Bora Way, F-320 Marina Del Rey, CA 90292 Tel: 310.478-5789 Fax: 509.561.6441 Email: hartpeter@msn.com * Additional Plaintiff's Counsel Listed On Following Page Attorneys for Plaintiff NICOLE VILLEGAS UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA NICOLE VILLEGAS, as an individual and on behalf of all others similarly situated, Plaintiff, vs. J.P. MORGAN CHASE & CO., a Delaware corporation; J.P. MORGAN CHASE BANK, N.A., a national association; CHASE BANK USA, N.A., a national association; and DOES 1 through 50, inclusive, Defendants. Case No. CV 09-00261 SBA CLASS ACTION JOINT STIPULATION AND ORDER CONTINUING PRE-TRIAL AND TRIAL DATE AND ANY ASSOCIATED DATES FOR FILING OF CLASS CERTIFICATION MOTION Judge: Hon. Saundra Brown Armstrong Room: 3, Third Floor Complaint Filed: December 18, 2008 DB2/21581299.1 STIPULATION TO CONTINUE PRE-TRIAL AND TRIAL DATE CASE NO. -- CV 09-00261 SBA 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 DB2/21581299.1 ADDITIONAL PLAINTIFF'S COUNSEL ERIC HONIG (State Bar No. 140765) LAW OFFICE OF ERIC HONIG P.O. Box 10327 Marina del Rey, California 90295 Telephone: (310) 314-2603 Facsimile: (310) 314-2793 erichonig@aol.com KENNETH H. YOON State Bar No. 198443 LAW OFFICES OF KENNETH H. YOON One Wilshire Blvd., Suite 2200 Los Angeles, CA 90017 (213) 612-0988 (213) 947-1211 facsimile kyoon@yoon-law.com LARRY W. LEE State Bar No. 228175 DIVERSITY LAW GROUP, A Professional Corporation 444 S. Flower Street Citigroup Center Suite 1370 Los Angeles, California 90071 (213) 488-6555 (213) 488-6554 facsimile lwlee@diversitylaw.com Attorneys for Plaintiff NICOLE VILLEGAS 1 STIPULATION TO CONTINUE PRE-TRIAL AND TRIAL DATE CASE NO. -- CV 09-00261 SBA 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Plaintiff Nicole Villegas ("Plaintiff") and Defendants JPMorgan Chase Bank, N.A., JPMorgan Chase & Co., Chase Bank USA, N.A. (collectively, "Defendants"), by and through their respective counsel of record named herein, hereby stipulate as follows: WHEREAS, after the April 29, 2009 Case Management Conference, this Court set a number of case deadlines in this matter; WHEREAS, the Parties have sought to continue the mediation in this matter due to conflicts with the past court-appointed mediators so that the Parties may have sufficient time to coordinate with a new court-appointed mediator; WHEREAS, on July 17, 2009 Plaintiff filed a motion to compel further responses to Interrogatories served on Defendants and to compel further responses and the production of further documents by Defendants; WHEREAS, the above discovery disputes were heard by Magistrate Judge Chen on September 2, 2009 and on October 7, 2009, with continued briefing ordered; WHEREAS, on December 2, 2009, Plaintiff filed further briefing papers on the above discovery issues as ordered by Magistrate Judge Chen and the Court held a further hearing on these discovery issues on January 27, 2010; WHEREAS, after the January 27, 2010 hearing, Magistrate Judge Chen issued certain limited discovery orders, ordered additional briefing from both parties, and also set a further hearing date for March 3, 2010; WHEREAS, due to the extended briefing of the discovery disputes and due to the recently discovered conflict with the court-appointed mediator the Parties seek to continue for a period of approximately six months the dates currently set by the Court, including the Pre-Trial date and the attending Trial Date, and any attending deadline to file a motion for class certification; WHEREAS, the Parties believe that such a continuance is needed to allow discovery to take place in a timely fashion and, after such discovery has taken place, to allow the Parties to properly mediate this case in an informed manner in the hopes of resolving this matter without a need for trial on these claims; THEREFORE, the Parties, through their undersigned respective counsel, stipulate and DB2/21581299.1 2 STIPULATION TO CONTINUE PRE-TRIAL AND TRIAL DATE CASE NO. -- CV 09-00261 SBA 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 request that the Court hereby order that, good cause appearing, the current dates in the Case Management Order be continued as follows: Event General Discovery Cut-off Expert Discovery Cut-off Plaintiff to Name Experts by Defendant to Name Experts by All Dispositive Motion to be heard by (Motion Cut-off) Pretrial Conference at 1:00 p.m. Pretrial Papers Due Motions in limine/objections to evidence due Responses to motions in limine and/or responses to objections to evidence due Reply to responses to motions in limine Trial (Court/Jury: 15-20 days) at 8:30 a.m. 3/29/2011 Old Deadlines New Deadline 7/6/2010 8/6/2010 7/6/2010 7/6/2010 8/10/2010 9/21/2010 8/31/2010 9/7/2010 9/14/2010 1/7/2011 2/9/2011 1/7/2011 1/7/2011 2/15/2011 4/5/2011 3/8/2011 3/15/2011 3/22/2011 10/4/2010 4/11/2011 Dated: March 3, 2010 Respectfully Submitted, MORGAN, LEWIS & BOCKIUS LLP By /s/ Carrie A. Gonell Carrie A. Gonell Attorneys for Defendants JPMORGAN CHASE & CO., JPMORGAN CHASE BANK, N.A., AND CHASE BANK USA, N.A. DB2/21581299.1 3 STIPULATION TO CONTINUE PRE-TRIAL AND TRIAL DATE CASE NO. -- CV 09-00261 SBA 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Dated: March 3, 2010 Respectfully Submitted, LAW OFFICES OF PETER M. HART By /s/ Peter M. Hart Peter M. Hart Attorneys for Plaintiff NICOLE VILLEGAS ORDER The parties having so stipulated, and GOOD CAUSE APPEARING THEREFORE, IT IS SO ORDERED. Date: 3/8/10 ______________________________ The Honorable Saundra B. Armstrong United States District Judge DB2/21581299.1 4 STIPULATION TO CONTINUE PRE-TRIAL AND TRIAL DATE CASE NO. -- CV 09-00261 SBA

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