UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION
April 24, 2013
SALVATORE AND SUSAN PILEGGI, INDIVIDUALLY AND ON BEHALF OF ALL OTHERS SIMILARLY SITUATED, PLAINTIFFS,
WELLS FARGO BANK, N.A., DEFENDANT.
The opinion of the court was delivered by: The Honorable William H. Alsup United States District Court Judge
STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DISCOVERY AND FILING OF SUPPLEMENTAL BRIEFS [CIVIL LOCAL RULES 6-2, 7-12]
Pursuant to Civil Local Rules 6-2(a) and 7-12, Plaintiffs Salvatore and Susan Pileggi and Defendant Wells Fargo Bank, N.A., by and through their respective counsel, hereby stipulate as 3 follows: 4
WHEREAS at the hearing on Plaintiffs' Motion for Class Certification on April 4, 2013, 5 the Court raised certain concerns about the motion and the issues addressed in the parties' 6 respective briefs. 7
WHEREAS the Court issued an order allowing the parties four weeks with which to 8 conduct "limited discovery" and to submit supplemental briefs that addressed its concerns. 9
WHEREAS, pursuant to this order, the parties must file their supplemental briefs by May 2, 2013, and response briefs by May 6, 2013. 11
WHEREAS Plaintiffs have propounded certain discovery; Wells Fargo has commenced 12 the production of information in response to those requests; and the parties have met and 13 conferred about the scope of the requests, the information to be provided, and the timing of the 14 production. 15
WHEREAS, as more fully explained in the accompanying Declaration of Jason A. Pikler, 16 the parties have come to realize that four weeks will not be sufficient to enable the parties to 17 produce and review the requested documents, to conduct the necessary depositions, and to 18 analyze the resulting deposition transcripts prior to filing the supplemental brief. 19
NOW, THEREFORE, the parties stipulate, subject to the Court's approval, to extend by 30 days the time allotted to complete the limited discovery ordered by the Court and the deadline 21 for submitting the supplemental briefs. The parties shall file their supplemental briefs by June 3, 22 2013, and response briefs by June 7, 2013. 23
IT IS SO STIPULATED.
Dated: April 22, 2013 SCHUBERT JONCKHEER & KOLBE LLP ___/s/ Jason A. Pikler______ 3 By: Jason A. Pikler 4 Three Embarcadero Center, Suite 1650 5 San Francisco, California 94111 Telephone: (415) 788-4220 6 Facsimile: (415) 788-0161 NEWMAN FERRARA LLP Jeffrey M. Norton 7 Randolph M. McLaughlin 1250 Broadway, 27th Fl. 8 9 New York, NY 10001 Telephone: (212) 619-5400 10 Facsimile: (212) 619-3090 11 Counsel for Plaintiffs 12 13 Dated: April 22, 2013 SEVERSON & WERSON ___/s/ Charles D. Marshall______ 14 15 By: Charles D. Marshall 16 One Embarcadero Center, Suite 2600 San Francisco, California 94111 17 Telephone: (415) 398-3344 Fax: (415) 956-0439 Counsel for Defendant
I, Jason A. Pikler, am the ECF User whose ID and password are being used to file this Stipulation. In compliance with Civil Local Rule 5-1(i)(3), I hereby attest that I have on file the 22 concurrences for any signatures indicated by a "conformed" signature (/s/) within this efiled 23 document. 24 25
Dated: April 22, 2013 ___/s/ Jason A. Pikler______ 26 27 28 By: Jason A. Pikler
PURSUANT TO THE STIPULATION OF THE PARTIES, IT IS SO ORDERED:
1. The parties shall have an additional 30 days to complete the limited discovery 4 ordered by the Court and to file their supplemental briefs. 5
2. The parties shall file their supplemental briefs by June 3, 2013.
3. The parties shall file any response briefs by June 7, 2013.
Ordered this ____ day of _____________, 2013
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