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Rancisco Ttorneys v. Freedom Financial Network

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION


June 29, 2011

RANCISCO TTORNEYS
HAIDEE ESTRELLA, AN INDIVIDUAL, AND
ENWICK 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.

KEVIN P. MUCK (CSB NO. 120918) kmuck@fenwick.com 2 CHRISTOPHER J. STESKAL (CSB NO. 212297) csteskal@fenwick.com JENNIFER BRETAN (CSB NO. 233475) jbretan@fenwick.com MARIE C. BAFUS (CSB NO. 258417) mbafus@fenwick.com FENWICK & WEST LLP 555 California Street, 12th Floor San Francisco, CA 94104 Telephone: (415) 875-2300 Facsimile: (415) 281-1350 Attorneys for Defendants Freedom Financial Network, LLC, Freedom Debt Relief, Inc. and Freedom Debt Relief, LLC

STIPULATION AND [PROPOSED] ORDER MODIFYING CERTAIN DEADLINES

WHEREAS, pursuant to prior orders of the Court, certain deadlines, including deadlines 2 for disclosure of experts, completion of expert discovery, and filing of dispositive motions, are 3 upcoming; 4

WHEREAS, on June 24, 2011, the Court took under submission Defendants' Motion to Compel Arbitration and to Stay Action Pursuant To The Federal Arbitration Act;

WHEREAS, in light of the Court taking the Motion to Compel Arbitration and To Stay 7 under submission, the parties believe that the interests of efficiency and economy would best be 8 served by extending the upcoming deadlines for a period of two weeks, and that such an 9 extension could avoid potentially unnecessary litigation costs;

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 and the deadline for the filing of dispositive motions, set per the Court's Orders of June 21, 2011 and October 27, 2010, respectively, be modified as follows:

(a) Defendants' Designation of Experts will move to July 11, 2011;

(b) Plaintiffs' Expert Rebuttal will move to July 28, 2011;

(c) Expert Discovery Cutoff will move to August 15, 2011.

(d) Dispositive Motions will be filed by August 5, 2011; Opposition will be due August 19, 2011; Reply will be due August 26, 2011; and hearing shall be set no later than September 9, 2011.

2. All other dates set pursuant to the Court's Pretrial Preparation Order of October 27, 2010 shall remain in place. 24

3. This Stipulation is without prejudice to any party's ability to seek a further stay or 25 other relief in light of any order the Court may issue on the Motion to Compel Arbitration and to 26 Stay Action.

Pursuant to General Order No. 45 Section X(B), all of the signatories concur in the filing of this 21 stipulation. 22 Dated: June 25, 2011 FENWICK & WEST LLP 23 By: /s/ Jennifer C. Bretan Jennifer C. Bretan

[PROPOSED] ORDER

PURSUANT TO STIPULATION, IT IS HEREBY ORDERED THAT: 3

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 4, 2011, shall be modified as follows:

(a) The deadline for Defendants' Designation of Experts is July 11, 2011;

(b) The deadline for Plaintiffs' Expert Rebuttal is July 28, 2011;

(c) Expert Discovery Cutoff is August 15, 2011.

(d) Dispositive Motions shall be filed by August 5, 2011; Opposition shall be due August 19, 2011; Reply shall be due August 26, 2011; and hearing shall be set no later than September 9, 2011.

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

20110629

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