IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION
November 22, 2011
JEFFREY SCHULKEN AND JENIFER SCHULKEN, INDIVIDUALLY AND ON BEHALF OF A CLASS OF SIMILARLY SITUATED INDIVIDUALS,
WASHINGTON MUTUAL BANK, HENDERSON, NEVADA; JPMORGAN CHASE BANK, N.A.,
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 firstname.lastname@example.org 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 email@example.com 11 firstname.lastname@example.org 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.
WHEREAS, on October 13, 2011, the Court held a hearing on Plaintiffs'
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 certification; 15 16 approval, that the above deadlines are extended approximately 45 days as follows:
WHEREAS, the Parties are not certain as to what expert discovery may be needed or
WHEREAS, in the interest of judicial economy and so that they may focus discovery
In light of the foregoing, the Parties hereby stipulate and agree, subject to this Court's Additional expert disclosures: January 6, 2012 Additional rebuttal expert disclosures: January 20, 2011 Discovery cut-off: February 27, 2012
Deadline for additional dispositive motions: March 12, 2012 March 5, 2012 Hearing on dispositive motions: April 19, 2012, at 1:30 pm April 12, 2012 at 1:30 pm Pretrial conference: May 30, 2012, at 2:00 pm
Trial: June 18, 2012, at 9:00 am. Trial length is estimated at 10 days.
This Stipulation is made in good faith and not for the purposes of delaying this litigation.
Pursuant to the stipulation,
IT IS SO ORDERED.
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