The opinion of the court was delivered by: Hon. Saundra B. Armstrong
JOINT STIPULATION TO MODIFY 21
BRIEFING SCHEDULE AND HEARING DATE 22
(collectively, "Plaintiffs") and defendant Aurora Loan Services, LLC ("Aurora") (collectively, the 3 Plaintiffs Mauder and Alice Chao, Deogeneso and Glorina Palugod, and Maritza Pinel "Parties") hereby stipulate and agree, and request the Court modify the pre-trial schedule, as 4 follows. 5 6 known as "special forbearance agreements." The Parties incorporate by reference their respective 7 factual statements of the case from their prior joint submissions. See Doc. ## 59, 92, 132 8 9 filed their Renewed Motion for Class Certification. Doc. # 149 ("Renewed Motion"). 10 11 named Plaintiffs. Additionally, Judge Beeler has ordered Aurora to produce certain payment data 12 Under the current schedule, Aurora's opposition to the Renewed Motion is due on December 28, 2012. See Doc. # 136. 15 Plaintiffs' requests for additional data, Aurora believes a brief extension of its deadline to oppose 17 This putative class action concerns Aurora's mortgage loan "workout agreements," also On November 16, 2012, pursuant to the existing pre-trial schedule (Doc. # 136), Plaintiffs Since Plaintiffs filed their Renewed Motion, Aurora has taken the depositions of each of the (Doc. # 155), and Plaintiffs have served an additional interrogatory seeking more payment data.
In light of the upcoming holidays, the press of work following the recent depositions, and Plaintiffs' Renewed Motion for Class Certification is warranted. Plaintiffs do not object to Aurora's 18 request, so long as they are given additional time to file their reply brief in support of the Renewed 19 Motion. Accordingly, the Parties hereby request that the Court amend the existing briefing 20 schedule and reschedule the existing hearing date as follows:
Matter Current Date*fn1 Proposed Date
Aurora files Opposition to Renewed Motion 4 for Class Certification December 28, 2012 January 7, 2012 5 Plaintiffs file Reply in Support of Renewed Motion for Class Certification January 21, 2012 January 30, 2012 6 January 29, 2013, at 1:00 p.m. (or as Class Certification Hearing at 1:00 p.m. otherwise set by the 8 Court)
February 12, 2013 for Plaintiffs and Aurora, upon consent of the Court, that:
IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel
The briefing schedule and hearing date are MODIFIED as set forth herein.
Date: December 11, 2012 ARNOLD & PORTER LLP 15 By: /s/ John R. Danos John R. Danos JOHN R. DANOS (CA SBN 210964) email@example.com ARNOLD & PORTER LLP 777 South Figueroa, 44th Floor Los Angeles, CA 90017-5844 Telephone: 22.214.171.12400 Facsimile: 126.96.36.19999 DAVID B. BERGMAN (pro hac vice) firstname.lastname@example.org IAN S. HOFFMAN (pro hac vice) email@example.com ARNOLD & PORTER LLP 555 Twelfth Street, NW Washington, DC 20004-1206 Telephone: 1 202.942.5000 Facsimile: 1.202.942.5999 Attorneys for Defendant Aurora Loan Services, LLC
Date: December 11, 2012 HAGENS BERMAN SOBOL SHAPIRO LLP 2 By: /s/ Thomas E. Loeser Thomas E. Loeser Steve W. Berman (Pro Hac Vice) Thomas E. Loeser (202724) HAGENS BERMAN SOBOL SHAPIRO LLP 1918 Eighth Avenue, Suite 3300 Seattle, WA 98101 (206) 623-7292 firstname.lastname@example.org email@example.com Andrew Oldham (144287) LAW OFFICE OF ANDREW OLDHAM 901 Campisi Way, Suite 248 Campbell, CA 95008 Telephone: (888) 842-4930 T. Christopher Tuck RICHARDSON, PATRICK, WESTBROOK & BRICKMAN, LLC 1037 Chuck Dawley Blvd., Bldg A PO Box 1007 Mt. Pleasant, SC 29464 (843) 727-6515 16 firstname.lastname@example.org 17 Ali Abtahi (224688) Idene Saam (258741) 18 ABTAHI LAW FIRM 1528 S. El Camino Real, Suite 204 San Mateo, CA 94402 Tel: (650) 341-1300 19 20 Fax: (650) 341-1303 email@example.com firstname.lastname@example.org 22 Attorneys for Plaintiffs and the proposed Class