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Rancisco Ttorneys v. Freedom Financial Network

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


February 22, 2011

RANCISCO TTORNEYS EST AW L T & W A HAIDEE ESTRELLA, AN INDIVIDUAL, AND
ENWICK AN S ANGELICA ARITA, AN INDIVIDUAL, ON BEHALF A OF THEMSELVES AND ALL OTHERS SIMILARLY SITUATED,
AND ON BEHALF OF THE GENERAL PUBLIC,
PLAINTIFFS,
v.
FREEDOM FINANCIAL NETWORK, LLC A
DELAWARE LIMITED LIABILITY COMPANY; FREEDOM DEBT RELIEF, INC., A CALIFORNIA CORPORATION; FREEDOM DEBT RELIEF, LLC, A DELAWARE LIMITED LIABILITY COMPANY;
GLOBAL CLIENT SOLUTIONS, LLC; ROCKY MOUNTAIN BANK AND TRUST; ANDREW HOUSSER; AND BRADFORD STROH AND DOES 1 THROUGH 100, DEFENDANTS.

The opinion of the court was delivered by: Hon. Susan Illston United States District Court Judge

STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE

WHEREAS, on January 21, 2011, Plaintiffs Haidee Estrella and Angelica Arita("Plaintiffs") and Defendants Freedom Debt Relief, LLC, Freedom Debt Relief, Inc., Freedom Financial Network, LLC, Andrew Housser and Brad Stroh (collectively, the "Freedom Defendants") each moved for partial summary judgment and/or summary adjudication with respect to a central claim in this matter ("the Motions");

WHEREAS, the hearing on the Motions is scheduled for February 25, 2011 at 9:00 a.m;

WHEREAS, the Plaintiffs and the Freedom Defendants have also agreed to a further settlement conference with the Magistrate Judge Joseph C. Spero set for April 27, 2011;

WHEREAS, Plaintiffs and Defendants Rocky Mountain Bank & Trust and Global ClientSolutions have entered into a tentative settlement agreement with the Class and are still in the 11 process of putting together the proposed agreement for submission to the Court;

WHEREAS, the parties respectfully submit that it is therefore in the interest of judicial economy and efficiency to continue the February 25, 2011 Case Management Conference to May 6, 2011, a date which will provide time for the Court to render its decision on the Motions and for Plaintiffs and the Freedom Defendants to have participated in the further settlement conference;

LLP

EST

AW L

RANCISCO

T

& W

A

14

F

ENWICK

TTORNEYS

AN S A

F

IT IS ACCORDINGLY STIPULATED, pursuant to Civil L.R. 7-12, by and between the undersigned counsel for the Parties that:

1. Pursuant to Civil L.R. 16-2, the Case Management Conference scheduled forFebruary 25, 2011 be vacated and rescheduled to May 6, 2011 at 3:00 p.m., or such other time as the Court shall determine to be appropriate; and

2. The associated Joint Case Management Statement deadline shall likewise be deferred for submission consistent with Civil L.R. 16-10(d).

Dated: February 16, 2011 KERSHAW, CUTTER, & RATINOFF LLP CLARK & MARKHAM LLP LAW OFFICES OF BARRON E. RAMOS CHARLES E. AMES, P.C. THE CROSLEY LAW FIRM, P.C. WEXLER WALLACE LLP

By: Stuart C. Talley Attorneys for Plaintiffs HAIDEE ESTRELLA and ANGELICA ARITA Dated: February 16, 2011 FENWICK & WEST LLP 9 By: Kevin P. Muck Kevin P. Muck Attorneys for Defendants FREEDOM FINANCIAL NETWORK, LLC, LLP FREEDOM DEBT RELIEF, INC. and FREEDOM DEBT RELIEF, LLC EST AW L RANCISCO T & W A Dated: February 16, 2011 LAW OFFICES OF ALLEN RUBY F ENWICK TTORNEYS AN S A By: Allen Ruby Allen Ruby F Attorneys for Defendants BRADFORD STROH and ANDREW HOUSSER Dated: February 16, 2011 GREENSPOON MARDER, P.A. 19 20 By: Richard W. Epstein Richard W. Epstein Attorneys for Defendants GLOBAL CLIENT SOLUTIONS, LLC & ROCKY MOUNTAIN BANK & TRUST Pursuant to General Order No. 45 Section X(B), all of the signatories concur in the filing of this 24 stipulation. 25 Dated: February 17, 2011 FENWICK & WEST LLP 26 By: Jennifer C. Bretan Jennifer C. Bretan

PURSUANT TO STIPULATION, IT IS HEREBY ORDERED THAT: 3

1. Pursuant to Civil L.R. 16-2, the Case Management Conference scheduled for

February 25, 2011 be vacated and rescheduled to May 6, 2011 at 3:00 p.m., or such other time as 5 the Court shall determine to be appropriate; and

2. The associated Joint Case Management Statement deadline shall likewise be deferred for submission consistent with Civil L.R. 16-10(d).

LLP EST RANCISCO AW L T & W A F ENWICK TTORNEYS AN S A

20110222

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