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Yesenia Guitron; and Judi Klosek v. Wells Fargo Bank

December 16, 2011

YESENIA GUITRON; AND JUDI KLOSEK,
PLAINTIFFS,
v.
WELLS FARGO BANK, N.A.; WELLS FARGO & CO.; PAM RUBIO; AND DOES 1-20,
DEFENDANTS.



The opinion of the court was delivered by: Hon. Claudia Wilken U.S. District Judge

Yosef Peretz (SBN 209288) Emily A. Knoles (SBN 241671) Michael D. Burstein (SBN 248516) PERETZ & ASSOCIATES 22 Battery Street, Suite 202 San Francisco, CA 94111 Telephone: 415.732.3777 Facsimile: 415. 372.3791 Attorneys for Plaintiffs YESENIA GUITRON and JUDI KLOSEK Baldwin J. Lee (Bar No. 187413) Alexander Nestor (Bar No. 202795) Amy Morgenstern (Bar No. 267412) ALLEN MATKINS LECK GAMBLE MALLORY & NATSIS LLP Three Embarcadero Center, 12th Floor San Francisco, CA 94111-4074 Phone: (415) 837-1515 Fax: (415) 837-1516 E-Mail:blee@allenmatkins.com anestor@allenmatkins.com amorgenstern@allenmatkins.com Attorneys for Defendants WELLS FARGO BANK, N.A., WELLS FARGO & CO. AND PAM RUBIO

PARTIES' STIPULATION AND [PROPOSED] ORDER TO EXTEND PRE-TRIAL EXCHANGE DEADLINE

Plaintiffs YESENIA GUITRON and JUDI KLOSEK and Defendants WELLS FARGO BANK, N.A., WELLS FARGO & CO. and PAM RUBIO stipulate as follows:

WHEREAS, the pre-trial exchange and related pre-trial deadlines set by the Court's Order for Pretrial Preparation commence on January 3, 2012 (Dkt. No. 18);

WHEREAS the parties will not have completed expert discovery by January 3, 2012;

WHEREAS Defendants' Motion to Sever and Motion for Summary Judgment, or in the Alternative Partial Summary Judgment, currently are pending before the Court, and the hearing 8 date has been continued to January 5, 2012, which is after the current deadline for pre-trial 9 exchange;

WHEREAS the next case management conference was continued from December 15, 2011 to January 5, 2012, together with the hearing date for Defendants' motions;

WHEREAS the parties believe they cannot complete the pre-trial exchange and related pre-trial requirements given the issues set forth above;

THEREFORE, the parties stipulate and respectfully ask the Court to extend the pre-trial exchange currently due on January 3, 2012, pursuant to the Order for Pre-Trial Preparation Order (Dkt. No. 18) to January 27, 2012.

IT IS SO STIPULATED THROUGH COUNSEL OF RECORD:

[PROPOSED] ORDER

Pursuant to the parties' Stipulation, and Good Cause appearing therefor, the Court 4 hereby orders that the pre-trial exchange currently due on January 3, 2012, pursuant to the 5 Order for Pre-Trial Preparation Order (Dkt. No. 18) is continued to January 27, 2012, and the other pre-trial deadlines set forth in the Order for Pre-Trial Preparation Order are continued accordingly. 7 8

IT IS SO ORDERED.

Dated: December ...


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