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

June 21, 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

STIPULATION AND [PROPOSED] ORDER MODIFYING CERTAIN EXPERT DISCOVERY DEADLINES

WHEREAS, on May 4, 2011, the Court issued an order setting certain deadlines related to expert discovery, a copy of which is attached hereto as Exhibit A;

WHEREAS, the parties subsequently, by letter agreement, agreed to extend the deadline for plaintiffs' expert designations to May 31, 2011;

WHEREAS, in light of scheduling issues, the parties have agreed to further modify the cutoff and designation dates related to certain remaining expert discovery;

WHEREAS, such modifications will not affect any other dates set by the Court;

IT IS ACCORDINGLY STIPULATED, pursuant to Civil L.R. 6-1(b), 6-2(a), and 7-12 by and between the undersigned counsel for the Parties that:

1. Pursuant to Civil L.R. 6-2(a), the cutoff and designation dates related to certain expert discovery, set per the Court's Order of May 5, 2011, be further modified as follows:

(a) Defendants' Designation of Experts will move to June 27,2011;

(c) Plaintiffs' Expert Rebuttal will move to July 14, 2011;

(d) Expert Discovery Cutoff will move to August 1, 2011.

2. All other dates set pursuant to the Court's Pretrial Preparation Order of October 27, 2010 shall remain in place.

Dated: June 17, 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: June 17, 2011 FENWICK & WEST LLP 25 By: Kevin P. Muck Attorneys for Defendants FREEDOM FINANCIAL NETWORK, LLC, FREEDOM DEBT RELIEF, INC. and FREEDOM DEBT RELIEF, LLC Dated: June 17, 2011 SKADDEN, ARPS, SLATE, MEAGHER & FLOM LLP By: Allen Ruby Attorneys for Defendants BRADFORD STROH and ANDREW HOUSSER Dated: June 17, 2011 GREENSPOON MARDER, P.A. 6 By: Richard W. Epstein Attorneys for Defendants GLOBAL CLIENT SOLUTIONS, LLC and ROCKY MOUNTAIN BANK &TRUST Pursuant to General Order No. 45 Section X(B), all of the signatories concur in the filing of this stipulation. 11 12 Dated: June 17, 2011 FENWICK & WEST LLP By: Jennifer C. Bretan

[PROPOSED] ORDER PURSUANT TO STIPULATION, IT IS HEREBY ORDERED THAT:

1. Pursuant to Civil L.R. 6-2(b), the cutoff and designation dates related to certain expert discovery, set per the Court's Order of May ...


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