Fowler v. Wells Fargo Bank, N.A.

Filing 57

ORDER by Judge Haywood S. Gilliam, Jr. Granting 56 Joint Stipulation to Stay Deadlines in Scheduling Order Pending Mediation. (ndrS, COURT STAFF) (Filed on 11/21/2017)

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1 MCGUIREWOODS LLP DAVID S. REIDY SBN #225904 2 Two Embarcadero Center Suite 1300 3 San Francisco, CA 94111-3821 Telephone: (415) 844-9944 4 Facsimile: (415) 844-9922 5 K. Issac deVyver (appearing pro hac vice) Karla L. Johnson (appearing pro hac vice) 6 Tower Two-Sixty 260 Forbes Avenue, Suite 1800 7 Pittsburgh, PA 15222-3142 Telephone: (412) 667-6000 8 Facsimile: (412) 667-6050 9 Sara F. Holladay-Tobias (appearing pro hac vice) 50 North Laura Street, Suite 3300 10 Jacksonville, FL 32202 Telephone: (904) 798-3200 11 Facsimile: (904) 798-3207 12 Attorneys for Defendant Wells Fargo Bank, N.A. 13 14 15 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION 16 17 VANA FOWLER, individually and on behalf of all others similarly situated, 18 Plaintiff, 19 vs. 20 WELLS FARGO BANK, N.A., 21 Defendant. 22 CASE NO. 3:17-cv-02092-HSG 4 JOINT STIPULATION TO STAY DEADLINES IN SCHEDULING ORDER PENDING MEDIATION AND [PROPOSED] ORDER The Hon. Haywood S. Gilliam, Jr. 23 24 25 26 27 28 JOINT STIPULATION TO STAY DEADLINES IN SCHEDULING ORDER PENDING MEDIATION 1 Pursuant to Civil Local Rules 6-2 and 7-12, Plaintiff Vana Fowler and Defendant Wells 2 Fargo Bank, N.A., hereby stipulate through their respective counsel of record as follows: 3 WHEREAS, on October 9, 2017, the parties submitted a Stipulated Case Schedule [D.E. 4 49]; 5 WHEREAS, on October 13, 2017, the Court issued a Scheduling Order [D.E. 50]; 6 WHEREAS, the parties have agreed to mediate this case before Hon. Daniel Weinstein 7 (Ret.) on January 15, 2018; 8 WHEREAS, the parties believe a stay of all deadlines in this case will aid the parties in 9 their efforts to resolve this litigation and avoid any unnecessary time and expense associated with 10 meeting the existing deadlines in the event this case is resolved at mediation; 11 WHEREAS, the parties have exchanged sufficient written discovery, including class 12 discovery, to have informed and productive settlement discussions; 13 WHEREAS, the parties believe that it will be more productive for the parties to focus on 14 mediation, rather than incurring the cost and expense of additional discovery, including 15 depositions and expert discovery; 16 WHEREAS, the next deadlines in this case are Amendment of Pleadings due December 17 11, 2017; Plaintiff’s Expert Report due December 31, 2017; Close of Fact Discovery due January 18 19, 2018; and Defendant’s Expert Report due January 31, 2017 [D.E. 50]; 19 WHEREAS, if the parties are unable to fully resolve this case at mediation, the Parties will 20 submit a proposed schedule to the Court no later than one week following mediation to address 21 any deadlines affected by this stay; 22 WHEREAS, the parties have not previously requested an extension of the deadlines in the 23 Scheduling Order and have mutually agreed to the proposed stay; 24 NOW THEREFORE the parties through their undersigned counsel hereby stipulate to, and 25 respectfully request the Court to order, that the deadlines set forth in the Court’s Scheduling Order 26 [D.E. 50] be stayed until the parties complete mediation on January 15, 2018. 27 IT IS SO STIPULATED. 28 1 JOINT STIPULATION TO STAY DEADLINES IN SCHEDULING ORDER PENDING MEDIATION 1 2 3 DATED: November 20, 2017 4 5 /s/ Michael F. Ram 6 Michael F. Ram Robins Kaplan, LLP 7 2440 W El Camino Real, Suite #100 8 Mountain View, CA 94040 9 Counsel for Plaintiff Vana Fowler _ /s/ K. Issac deVyver K. Issac deVyver McGuireWoods LLP Tower Two-Sixty 260 Forbes Avenue, Suite 1800 Pittsburgh, PA 15222-3142 Counsel for Defendant Wells Fargo Bank, N.A. 10 11 PURSUANT TO STIPULATION, IT IS SO ORDERED. 12 13 14 15 Dated: 11/21/2017 Honorable Haywood S. Gilliam, Jr. United States District Judge 16 17 18 19 20 21 22 23 24 25 26 27 28 2 JOINT STIPULATION TO STAY DEADLINES IN SCHEDULING ORDER PENDING MEDIATION 1 2 ATTESTATION I, K. Issac de Vyver, am the ECF user whose identification and password are being used to 3 file this Joint Stipulation to Stay Deadlines in Scheduling Order Pending Mediation and 4 [Proposed] Order. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that Michael F. 5 Ram concurs in this filing. 6 7 DATED: November 20, 2017 8 McGUIREWOODS LLP By: /s/ K. Issac deVyver 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 JOINT STIPULATION TO STAY DEADLINES IN SCHEDULING ORDER PENDING MEDIATION

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