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Jeffrey Schulken and Jenifer Schulken v. Washington Mutual Bank

November 22, 2011

JEFFREY SCHULKEN AND JENIFER SCHULKEN, INDIVIDUALLY AND ON BEHALF OF A CLASS OF SIMILARLY SITUATED INDIVIDUALS,
PLAINTIFFS,
v.
WASHINGTON MUTUAL BANK, HENDERSON, NEVADA; JPMORGAN CHASE BANK, N.A.,
DEFENDANTS.



The opinion of the court was delivered by: Lucy H. Koh United States District Judge

Sean P. Reis (Cal. Bar. No. 184044) EDELSON MCGUIRE, LLP 2 Lakeview Tower 30021 Tomas Street, Suite 300 3 Rancho Santa Margarita, CA 92688 Telephone: (949) 459-2124 4 Facsimile: (949) 459-2123 sreis@edelson.com 5 Attorneys for Plaintiffs, 6 JEFFREY AND JENIFER SCHULKEN 7 GEORGE G. WEICKHARDT (SBN 58586) WENDY C. KROG (SBN 257010) 8 ROPERS, MAJESKI, KOHN & BENTLEY 201 Spear Street, Suite 1000 9 San Francisco, CA 94105-1667 Telephone: (415) 543-4800 10 Facsimile: (415) 972-6301 gweickhardt@rmkb.com 11 wkrog@rmkb.com 12 Attorneys for Defendant, JPMORGAN CHASE BANK, N.A. 13 [additional counsel appear on signature page] 14

STIPULATION AND PROPOSED ORDER TO CONTINUE DISCOVERY DEADLINES

Fifth Am. Complaint filed:10/14/2011 Judge: Hon. Lucy H. Koh

WHEREAS, on July 27, 2011, the Court issued an Order setting a schedule for the 23 remaining discovery in this case, as follows: 24

Additional expert disclosures: November 22, 2011

Additional rebuttal expert disclosures: December 6, 2011

Discovery cut-off: January 12, 2012

Deadline for additional dispositive motions: January 26, 2012

Hearing on dispositive motions: March 1, 2012, at 1:30 pm

Pretrial conference: April 11, 2012, at 2:00 pm

Trial: April 30, 2012, at 9:00 am. Trial length is estimated at 10 days.

(Dkt. 133).

WHEREAS, on October 13, 2011, the Court held a hearing on Plaintiffs' Motion for Class Certification which the Court took under advisement; 7 filed their Fifth Amended Complaint, to which Defendant JPMorgan Chase Bank, N.A. 9

Whereas, on October 14, 2011, Plaintiffs Jeffrey and Jennifer Schulken ("Plaintiffs") ("Defendant") filed its Answer on October 28, 2011; 10 11 relevant following this Court's ruling on Plaintiffs' Motion for Class Certification; 12 13 on relevant matters only, the Parties seek a 45-day extension of the above deadlines, pending 14 the Court's consideration of the motion for class ...


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