Ralston .v Mortgage Investors Group, Inc., et.al.

Filing 304

STIPULATION AND ORDER EXTENDING PAGE LIMIT FOR PLAINTIFF'S REPLY TO OPPOSITION OF MORTGAGE INVESTORS GROUP IN SUPPORT OF CORRECTED MOTION FOR CLASS CERTIFICATION (approving 302 ). Signed by Judge Jeremy Fogel on 10/5/2011. (jflc2, COURT STAFF) (Filed on 10/5/2011)

1 Lori E. Andrus

[e-mail]

2 Jennie Lee Anderson

[e-mail]

3 ANDRUS ANDERSON LLP

155 Montgomery Street, Suite 900

4 San Francisco, CA 94104
5 David M. Arbogast

[e-mail]

6 Jeffrey K. Berns

[e-mail]

7 ARBOGAST & BERNS LLP

6303 Owensmouth Ave., 10th Floor

8 Woodland Hills, CA 91367
9 Attorneys for Plaintiff
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN JOSE DIVISION

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JAY RALSTON, individually and on behalf of

14 all others similarly situated,
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Plaintiff,
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v.

17 MORTGAGE INVESTORS GROUP, INC.;
MORTGAGE INVESTORS GROUP, a general
18 partnership; COUNTRYWIDE HOME LOANS,
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INC. AND DOES 3-10,

Case No. 08-CV-00536 JF (PSG)
STIPULATION AND [PROPOSED]
ORDER EXTENDING PAGE LIMIT FOR
PLAINTIFF’S REPLY TO OPPOSITION
OF MORTGAGE INVESTORS GROUP IN
SUPPORT OF CORRECTED MOTION
FOR CLASS CERTIFICATION
Courtroom: 3 - 5th Floor
Judge:
Hon. Jeremy Fogel

Defendants.

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STIPULATION EXTENDING PAGE LIMIT FOR REPLY BRIEF
CASE NO. 5:08-CV-00536-JF (PSG)

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STIPULATION AND [PROPOSED] ORDER EXTENDING PAGE LIMIT FOR PLAINTIFF’S REPLY TO
OPPOSITION OF MORTGAGE INVESTORS GROUP IN SUPPORT OF CORRECTED MOTION FOR
CLASS CERTIFICATION

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Plaintiff Jay Ralston (“Plaintiff”), and defendants Mortgage Investors Group, Inc. and

4 Mortgage Investors Group, a general partnership (collectively, “MIG,” and, together with Plaintiff,
5 the “Parties”), through their undersigned counsel, stipulate as follows:
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WHEREAS on June 8, 2011, the Court approved a stipulation among the Parties providing

7 for a five-page extension for Plaintiff’s Motion for Class Certification (“Motion”) (for a total of 30
8 pages); a five-page extension for MIG’s opposition to Plaintiff’s Motion (for a total of 30 pages);
9 and a three-page extension for Plaintiffs’ reply in further support of the Motion (for a total of 18
10 pages);
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WHEREAS, on October 4, 2011, Plaintiff requested and MIG agreed to a further 10-page

12 extension (for a total of 28 pages) for his class certification reply;
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WHEREAS, Plaintiff maintains that the additional 10 pages are necessary and appropriate

14 for him to address MIG’s opposition arguments and make a full and complete presentation of the
15 Court on the class certification issue;
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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED, between the

17 Parties, by their undersigned counsel, that Plaintiff shall have a total of 28 pages for his reply in
18 further support of his Motion for Class Certification.
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Respectfully submitted,

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-1STIPULATION EXTENDING PAGE LIMIT FOR REPLY BRIEF
CASE NO. 5:08-CV-00536-JF (PSG)

1 Dated: October 4, 2011

/s/ Jeffrey K. Berns
Lori E. Andrus
[e-mail]
Jennie Lee Anderson
[e-mail]
ANDRUS ANDERSON LLP
155 Montgomery Street, Suite 900
San Francisco, CA 94104

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David M. Arbogast
[e-mail]
Jeffrey K. Berns
[e-mail]
ARBOGAST & BERNS LLP
6303 Owensmouth Ave., 10th Floor
Woodland Hills, CA 91367

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Attorneys for Plaintiff:
Jay Ralston

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11 Dated: October 4, 2011

/s/ Roland P. Reynolds
Roland P. Reynolds
[e-mail]
PALMER, LOMBARDI & DONOHUE LLP
515 South Flower Street, Suite 2100
Los Angeles, CA 90071

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Attorneys for Defendants
Mortgage Investors Group, Inc. and Mortgage
Investors Group, A General Partnership

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[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED

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Dated: _____________________

_______________________________
Judge Jeremy Fogel

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CASE NO. 5:08-CV-00536-JF (PSG)

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ECF CERTIFICATION
Pursuant to General Order No. 45, § X.B., the filing attorney attests that he has obtained

3 concurrence regarding the filing of this document from the signatories to the document.
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Dated: October 4, 2011

ARBOGAST & BERNS LLP
6303 Owensmouth Ave., 10th Floor
Woodland Hills, CA 91367

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By: /s/Jeffrey K. Berns

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Attorneys for Plaintiff

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-3STIPULATION EXTENDING PAGE LIMIT FOR REPLY BRIEF
CASE NO. 5:08-CV-00536-JF (PSG)

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PROOF OF SERVICE

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I further certify that this document filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing
(NEF) and paper copies will be sent to those indicated as non registered participants on October 4,
2011.

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/s/ Jeffrey K. Berns
Jeffrey K. Berns

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-1STIPULATION EXTENDING PAGE LIMIT FOR REPLY BRIEF
CASE NO. 5:08-CV-00536-JF (PSG)