Stuart B. Wolfe (SBN 156471) Marcus T. Brown (SBN 255662) 2 firstname.lastname@example.org WOLFE & WYMAN LLP 3 2175 N. California Blvd., Suite 645 Walnut Creek, California 94596-3502 4 Telephone: (925) 280-0004 Facsimile: (925) 280-0005 5 Attorneys for Defendant 6 SAXON MORTGAGE SERVICES, INC. 7 8
WYMAN LLP Attorneys & Counselors At Law
ORDER STIPULATION AND [PROPOSED] ORDER CONTINUING DATES AND DEADLINES IN THE COURT'S CASE
COME NOW Plaintiff OSCAR MADRIGAL SENCION ("Plaintiff"), Defendant SAXON MORTGAGE SERVICES, INC. ("Saxon"), and Defendant OCWEN LOAN SERVICING, LLC 20 ("Ocwen") (collectively, "Parties") and hereby stipulate as follows.
WHEREAS, the Court entered a case management order on January 20, 2011, scheduling a 22 trial date, pretrial conference, and other dates and deadlines, including, but not limited to, a fact 23 discovery cut-off of May 2, 2011; 24
WHEREAS, Plaintiff thereafter filed his second amended complaint, which added a new 25 defendant, Deutsche Bank National Trust Company, as trustee ("Deutsche Bank"); 26
WHEREAS, on April 8, 2011, the Court reassigned this case to the Honorable Jeremy Fogel;
WHEREAS, on April 11, 2011, the Court vacated the trial date and the pretrial conference date, apparently because of the judicial reassignment of the case;
WHEREAS, Deutsche Bank has not yet appeared in the case, and the time for Deutsche Bank to respond to the second amended complaint has not yet expired; and 3
WHEREAS, Saxon and Ocwen have commenced written discovery, but the parties believe 4 that conducting the additional necessary discovery, in particular the necessary depositions, before the 5 existing (May 2, 2011) fact discovery cutoff would be inefficient because the case is not yet entirely 6 at issue and there is now no trial date; 7
NOW, THEREFORE, the Parties stipulate and agree that each of the dates and deadlines in 8 the Court's January 20, 2011 case management order shall be continued 120 calendar days, as 9 follows: 10
1. Fact Discovery Cutoff: August 30, 2011;
2. Designation of Opening Experts with Reports: September 29, 2011;
3. Designation of Rebuttal Experts with Reports: ...