The opinion of the court was delivered by: The Honorable Elizabeth D. Laporte United States District Court Judge
[Declaration of James C. Rutten filed concurrently herewith]
STIPULATION AND [PROPOSED] ORDER CONTINUING DEADLINE TO SUBMIT DISCOVERY STIPULATION
WHEREAS the parties filed cross-motions to compel on October 19, 2010;
WHEREAS the Court held a hearing on the motions on December 7, 2010;
WHEREAS the Court provided guidance to the parties at the hearing on many of the disputed issues, and directed the parties to meet and confer further and to submit a stipulation by December 21, 2010 setting forth agreements reached during that further meet-and-confer process;
WHEREAS the parties have had extensive telephonic and written meet-and-confer discussions as directed by the Court;
WHEREAS those meet-and-confer discussions have been productive, in that the parties have reached agreements, which they are in the process of documenting, on many of the disputed issues;
WHEREAS the parties continue to meet and confer as to other issues raised by the motions to compel, and believe that additional time is needed to complete those meet-and-confer 13 discussions with a view to resolving as many of the disputes as possible;
WHEREAS the parties believe that, particularly in light of the December holidays, an additional nine days would be an appropriate amount of time to allow them to complete their discussions;
NOW THEREFORE, IT IS HEREBY STIPULATED BY AND BETWEEN THE
PARTIES HERETO AND THEIR COUNSEL OF RECORD THAT the deadline for the parties to submit a stipulation concerning the cross-motions to compel, as directed by the Court, shall be continued from December 21, 2010 to December 30, 2010.
Date: December 21, 2010 MUNGER, TOLLES & OLSON LLP By James C. Rutten Attorneys for Defendants WELLS FARGO BANK, N.A. (successor by merger to WACHOVIA BANK, N.A.) and METROPOLITAN WEST SECURITIES LLC
Date: December 21, 2010 BARGER & WOLEN LLP By Travis R. Wall Attorneys for Plaintiff STATE ...