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Ramirez v. Greenpoint Mortgage Funding

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


July 9, 2009

ANA RAMIREZ, ISMAEL RAMIREZ, AND JORGE SALAZAR, ON BEHALF OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
v.
GREENPOINT MORTGAGE FUNDING, INC., DEFENDANT.

The opinion of the court was delivered by: Judge: Honorable Thelton E. Henderson

CLASS ACTION

JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF CLASS CERTIFICATION DEADLINE

Expedited Treatment Requested

Pursuant to Civil Local Rules 6-2 and 7-12, plaintiffs Ana Ramirez, Ismael Ramirez, and Jorge Salazar and defendant GreenPoint Mortgage Funding, Inc. (collectively, the "Parties") hereby respectfully request that this Court extend Plaintiffs' deadline to file their class certification motion for 60 days until September 18, 2009.

In support of this Motion, the Parties represent that they have agreed to pursue the possible settlement of this matter with the assistance of a mediator and that they are in the process of scheduling a mediation session to be held in August 2009. A brief extension of time for the filing of Plaintiffs' class certification motion is in the interests of the efficient administration of justice as it may avoid unnecessary costs of litigation and burdens on the Court, and will permit the Parties to focus their efforts on seeking a potential resolution of this matter.

The Parties seek expedited treatment of this motion in order to avoid additional time and costs associated with meeting the current deadline for the motion for class certification including, without limitation, substantial expert costs.

DATED: July 8, 2009

SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP Raoul D. Kennedy (CA SBN 40892) Four Embarcadero Center, Suite 3800 San Francisco, California 93111-3133 Telephone: (415) 984-6400 Facsimile: 415-984-2698

Anand S. Raman (admitted pro hac vice) Amanda M. Raines (admitted pro hac vice) Colin D. Forbes (admitted pro hac vice) 1440 New York Avenue, N.W. Washington, D.C. 20005 Telephone: 202-371-7000 Facsimile: 202-393-5760 Attorneys for Defendant

BONNETT, FAIRBOURN, FRIEDMAN, & BALINT, P.C. Andrew S. Friedman (to be admitted pro hac vice) Wendy J. Harrison (CA SBN 151090) 2901 North Central Avenue, Suite 1000 Phoenix, Arizona 85012 Telephone: 602-274-1100

Gary Klein (admitted pro hac vice) Shennan Kavanagh RODDY KLEIN & RYAN 727 Atlantic Avenue Boston, MA 02111-2810 Telephone: 617-357-5500, ext. 15

CHAVEZ & GERTLER, L.L.P. Mark A. Chavez (CA SBN 90858) Nance F. Becker (CA SBN 99292) Dan Gildor (CA SBN 99292) 42 Miller Avenue Mill Valley, California 94941 Telephone: 415-381-5599

MILLER LAW LLC Marvin A. Miller (to be admitted pro hac vice) Lori A. Fanning (to be admitted pro hac vice) 115 South LaSalle Street, Suite 2910 Chicago, IL 60603 Telephone: (312) 332-3400

NATIONAL CONSUMER LAW CENTER Stuart T. Rossman (to be admitted pro hac vice) Charles Delbaum (to be admitted pro hac vice) 7 Winthrop Sq., 4th Fl. Boston, MA 02110 Telephone: (617) 542-8010

COUGHLIN STOIA GELLER RUDMAN & ROBBINS LLP John J. Stoia, Jr. (CA SBN 141757) Theodore J. Pintar (CA SBN 131372) Leslie E. Hurst (CA SBN 178432) 655 West Broadway San Diego, CA 92101-3301 Telephone: 619-231-1058 Attorneys for Plaintiffs

[PROPOSED] ORDER

Upon stipulation of the Parties, and good cause appearing, plaintiffs Ana Ramirez, Ismael Ramirez, and Jorge Salazar shall have through and including September 18, 2009 to file their class certification motion.

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Thelton E. Henderson United States District Court Judge

SIGNATURE ATTESTATION

I, Raoul Kennedy, am the ECF User whose ID and password and being used to file this JOINT STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF CLASS CERTIFICATION DEADLINE. In compliance with General Order 45, X.B., I hereby attest that Gary Klein has concurred in this filing.

20090709

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