May 20, 2013
SALVATORE AND SUSAN PILEGGI, Individually and on behalf of all others similarly situated, Plaintiffs,
WELLS FARGO BANK, N.A., Defendant.
MIRANDA P. KOLBE (S.B.N. 214392), JASON A. PIKLER, (S.B.N. 245722), SCHUBERT JONCKHEER & KOLBE LLP, San Francisco, California, JEFFREY M. NORTON, (pro hac vice), NEWMAN FERRARA LLP, New York, NY Counsel for Plaintiffs.
MARK D. LONERGAN, (S.B.N. 143622), CHARLES D. MARSHALL, (S.B.N. 236444), SEVERSON & WERSON, A Professional Corporation San Francisco, California, Counsel for Defendant Wells Fargo Bank.
STIPULATION AND [PROPOSED] ORDER TO EXTEND THE TIME FOR DISCOVERY AND FILING OF SUPPLEMENTAL BRIEFS BY AN ADDITIONAL SEVEN DAYS
CIVIL LOCAL RULES 6-2, 7-12
WILLIAM H. ALSUP, District Judge.
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 follows:
WHEREAS at the hearing on Plaintiffs' Motion for Class Certification on April 4, 2013, the Court raised certain concerns about the motion and the issues addressed in the parties' respective briefs.
WHEREAS the Court issued an order allowing the parties four weeks with which to conduct "limited discovery" and to submit supplemental briefs that addressed its concerns.
WHEREAS, due to the unexpected variety and complexity of Wells Fargo's computer systems and databases, the parties sought and received a 30-day extension of the deadlines to complete discovery and submit their supplemental briefs (Docket Nos. 45 and 46).
WHEREAS, as more fully explained in the accompanying Declaration of Jason A. Pikler, an additional week is needed to give the parties time to fully comply with the outstanding discovery requests, while allowing the parties sufficient time to finalize their supplemental briefs.
NOW, THEREFORE, the parties stipulate, subject to the Court's approval, to extend by seven days the time allotted to complete the limited discovery ordered by the Court and the deadline for submitting the supplemental briefs. The parties shall file their supplemental briefs by June 10, 2013, and response briefs by June 14, 2013.
IT IS SO STIPULATED.
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 concurrences for any signatures indicated by a "conformed" signature (/s/) within this efiled document.
PURSUANT TO THE STIPULATION OF THE PARTIES, IT IS SO ORDERED:
1. The parties shall have an additional seven (7) days to complete the limited discovery ordered by the Court and to file their supplemental briefs.
2. The parties shall file their supplemental briefs by June 10, 2013.
3. The parties shall file any response briefs by June 14, 2013.