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Jeffrey Schulken and Jenifer Schulken v. Washington Mutual Bank

December 3, 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 Lakeview Tower 30021 Tomas Street, Suite 300 Rancho Santa Margarita, CA 92688 Telephone: (949) 459-2124 Facsimile: (949) 459-2123 sreis@edelson.com Attorneys for Plaintiffs, JEFFREY AND JENIFER SCHULKEN GEORGE G. WEICKHARDT (SBN 58586) WENDY C. KROG (SBN 257010) ROPERS, MAJESKI, KOHN & BENTLEY 201 Spear Street, Suite 1000 San Francisco, CA 94105-1667 Telephone: (415) 543-4800 Facsimile: (415) 972-6301 gweickhardt@rmkb.com wkrog@rmkb.com Attorneys for Defendant, JPMORGAN CHASE BANK, N.A.

STIPULATION AND PROPOSED ORDER TO CONTINUE 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 2 continuation of discovery deadlines. (Dkt. 173.) The basis for the stipulation was that the 3 Court's ruling on Plaintiffs' Motion for Class Certification. The stipulation sought, in the 5 interest of judicial economy and so that the Parties could focus discovery on relevant matters 6 only, a 45-day extension of discovery and related deadlines, pending the Court's 7 consideration of the motion for class certification; 8

WHEREAS, on November 21, 2011, the Parties filed a stipulation seeking a Parties were not certain as to what expert discovery may be needed or relevant following this

WHEREAS, on November 22, 2011, this Court entered an Order modifying the Parties' proposed stipulated schedule and setting the following dates:

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 5, 2012

Hearing on dispositive motions: 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 ...


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