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Haidee Estrella, An Individual, and v. Freedom Financial Network

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


May 2, 2011

HAIDEE ESTRELLA, AN INDIVIDUAL, AND ANGELICA ARITA, AN INDIVIDUAL, ON BEHALF 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

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STIPULATION AND [PROPOSED] ORDER CONTINUING CASE MANAGEMENT CONFERENCE

Andrew Housser and Brad Stroh (collectively, the "Freedom Defendants") have agreed to a 4 further settlement conference with Magistrate Judge Joseph C. Spero set for April 27, 2011;

WHEREAS, Plaintiffs Haidee Estrella and Angelica Arita ("Plaintiffs") and Defendants Freedom Debt Relief, LLC, Freedom Debt Relief, Inc., Freedom Financial Network, LLC, 3

WHEREAS, Plaintiffs and Defendants Rocky Mountain Bank & Trust and Global Client Solutions have entered into a tentative settlement agreement with the Class and are still in the 7 process of putting together the proposed agreement for submission to the Court;

WHEREAS, the parties previously stipulated to an order continuing the original February 25, 2011 Case Management Conference to May 6, 2011, in order to provide time for the Court to 10 render its decision on the parties' cross motions for summary judgment; 11 motions;

WHEREAS, on March 14, 2011, the Court issued an order denying the parties' cross-

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WHEREAS, counsel for certain defendants now has a scheduling conflict on May 6,

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WHEREAS, the parties are in the process of completing fact discovery, which closes May 7, 2011, followed by expert discovery, which closes July 7, 2011; 17 18 economy and efficiency to continue the May 6, 2011 Case Management Conference to 19 July 15, 2011, at which time the parties expect to have completed discovery in this matter; 20 the undersigned counsel for the Parties that: 22

WHEREAS, the parties respectfully submit that it is therefore in the interest of judicial

IT IS ACCORDINGLY STIPULATED, pursuant to Civil L.R. 7-12, by and between

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

6, 2011 be vacated and rescheduled to July 15, 2011 at 3:00 p.m., or such other time as the Court 24 shall determine to be appropriate; and 25 deferred for submission consistent with Civil L.R. 16-10(d).

2. The associated Joint Case Management Statement deadline shall likewise be

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS HEREBY ORDERED THAT: 3

1. Pursuant to Civil L.R. 16-2, the Case Management Conference scheduled for May 6, 2011 be vacated and rescheduled to July 15, 2011 at 3:00 p.m., or such other time as the Court 5 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).

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© 1992-2011 VersusLaw Inc.



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