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Joseph Roling and Alexander Landvater, Individually and On Behalf of v. E*Trade Securities LLC

October 18, 2011

JOSEPH ROLING AND ALEXANDER LANDVATER, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
v.
E*TRADE SECURITIES LLC, A DELAWARE LIMITED LIABILITY COMPANY, AND DOES 1-50, INCLUSIVE,
DEFENDANTS.



The opinion of the court was delivered by: The Honorable Edward M. Chen

Sean Reis (SBN 184044) Edelson McGuire, LLP 2 30021 Tomas Street, Suite 300 3 Rancho Santa Margarita, California 92688 Tel: (949) 459-2124 4 Fax: (949) 459-2123 sreis@edelson.com 5 Rafey S. Balabanian (Admitted Pro Hac Vice) 6 Steven L. Lezell (Admitted Pro Hac Vice) 7 Ari J. Scharg (Admitted Pro Hac Vice) Edelson McGuire, LLC 8 350 North LaSalle, Suite 1300 Chicago, Illinois 60654 9 Tel: (312) 589-6370 10 Fax: (312) 589-6378 rbalabanian@edelson.com 11 slezell@edelson.com ascharg@edelson.com 12 13

STIPULATION TO EXTEND DISCOVERY DEADLINES

Plaintiffs Joseph Roling and Alexander Landvater (collectively "Plaintiffs"), and Defendant E*TRADE Securities, LLC ("E*TRADE") (Plaintiffs and E*TRADE are collectively 3 referred to as the "Parties"), pursuant to Fed. R. Civ. P. 6 and L.R. 7-12, hereby stipulate and 4 agree to extend the class discovery deadline by sixty (60) days, and modify the Discovery Plan.

1. Plaintiffs Joseph Roling and Alexander Landvater filed this putative class action 7 lawsuit against E*Trade Securities LLC on February 3, 2010. (Dkt. No. 1.)

(Dkt. No. 69.) In support of their Stipulation, the Parties state as follows:

2. As set forth in the Revised Discovery Plan, which was approved by the Court on February 2, 2011, discovery in this matter has been bifurcated into class and merits phases, with 10 class discovery closing on November 1, 2011. (Dkt. No. 69.)

12 case concerns a putative class that is potentially comprised of millions customers. As such, the Parties have exchanged thousands of documents relating to customer contracts and agreements 14 dating back to 2001, and are still in the process of producing relevant documents. Additionally, 15 several depositions still need to be taken, and Plaintiffs just received on Friday, October 14, firm 16 dates for certain Rule 30(b)(6) witnesses of E*Trade. 17

18 finish taking depositions, and also to issue any follow up discovery that may be necessary after 19 the depositions have been taken. 20

21 litigation." Zivkovic v. Southern California Edison Co., 302 F.3d 1080, 1087 (9th Cir. 2002). The 22 court may modify the discovery deadline only for good cause. Fed. R. Civ. P. 16(b)(4); Zivkovic, 23

302 F.3d at 1087. Good cause to extend a deadline exists when the deadline "cannot reasonably 24 be met despite the diligence of the party seeking the extension." Fed. R. Civ. P 16 Advisory 25

1992).

3. Good cause exists to extend the class discovery period by sixty (60) days. This

4. Extending the discovery cut-off date by sixty (60) days will allow the Parties to

5. The district court is given broad discretion in supervising the ...


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