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Jeffrey Schulken and Jenifer Schulken v. Washington Mutual Bank

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION


January 30, 2012

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: Judge: Hon. Lucy H. Koh

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 EXPERT DISCOVERY DEADLINES

Fifth Am. Complaint filed:10/14/2011

WHEREAS, on October 13, 2011, the Court held a hearing on Plaintiffs' Motion for Class Certification which the Court took under advisement; 24 Whereas, on October 14, 2011, Plaintiffs Jeffrey and Jennifer Schulken ("Plaintiffs") 25 filed their Fifth Amended Complaint, to which Defendant JPMorgan Chase Bank, N.A. 26 ("Defendant") filed its Answer on October 28, 2011; 27 28

WHEREAS, on December 30, 2011, the Parties file a proposed Stipulation asking the Court to continue discovery deadlines, including deadlines related to expert discovery. The 3 reason was, at that time, the Parties were uncertain as to what expert discovery may be 4 needed or relevant following this Court's ruling on Plaintiffs' Motion for Class Certification;

WHEREAS, on January 5, 2012, this Court entered an Order Granting in Part and Denying in Part Plaintiffs' Motion for Class Certification. 7

WHEREAS, the present deadlines for expert disclosures are set as follows: Additional Expert Disclosures Due February 3, 2012 Rebuttal Expert Disclosures Due February 17, 2012 Discovery cut-off: March 28, 2012

WHEREAS, the Parties, being in receipt of the Court's Order on the Motion for Class Certification and being focused on concluding merits discovery (and still discussing 13 settlement), seek an additional 30 day extension of certain of the relevant expert deadlines, 14 and propose new deadlines as follows (without any change to the Pretrial Conference or Trial 15 dates):

20 litigation.

Additional expert disclosures: March 2, 2012

Additional rebuttal expert disclosures: March 23, 2012

Discovery cut-off: March 30, 2012

This Stipulation is made in good faith and not for the purposes of delaying this

ORDER

Pursuant to the stipulation,

IT IS SO ORDERED.

Dated

UNITED STATES DISTRICT JUDGE LUCY H. KOH

20120130

© 1992-2012 VersusLaw Inc.



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