Opinion
Civ. Case No. 11-MC-80211 (Misc.) (JSW) (NMC)
11-30-2011
CITY OF ANN ARBOR EMPLOYEES' RETIREMENT SYSTEM, et al., Individually and On Behalf of All Others Similarly Situated, Plaintiffs, v. CITIGROUP MORTGAGE LOAN TRUST INC., et al., Defendants. (Pending in the U.S. District Court for the Eastern District of New York, No. 08-cv-1418)
MUNGER, TOLLES & OLSON LLP MARC T.G. DWORSKY DAVID H. FRY KATHLEEN M. McDOWELL AARON G. LEIDERMAN Kathleen M. McDowell Attorneys for Third Party WELLS FARGO BANK, N.A. ROBBINS GELLER RUDMAN & DOWD LLP THOMAS E. EGLER NATE LINDELL Thomas E. Egler Attorneys for Lead Plaintiffs CITY OF ANN ARBOR EMPLOYEES RETIREMENT SYSTEM and GREATER KANSAS CITY LABORERS PENSION FUND
MARC T.G. DWORSKY (SBN 157413)
KATHLEEN M. McDOWELL (SBN 115976)
MUNGER, TOLLES & OLSON LLP
DAVID H. FRY (SBN 189276)
AARON G. LEIDERMAN (SBN 262540)
MUNGER, TOLLES & OLSON LLP
Attorneys for Third Party
WELLS FARGO BANK, N.A.
CLASS ACTION
STIPULATION AND [PROPOSED]
ORDER RE TIMING OF WELLS
FARGO PRODUCTION OF
DOCUMENTS
[Supporting Declaration of Aaron G.
Leiderman filed concurrently herewith]
Magistrate Judge: Hon. Nathanael Cousins
WHEREAS, on November 14, 2011, this Court issued its Order Granting Motion to Compel (Dckt #12) directing non-party Wells Fargo Bank, N.A. ("Wells Fargo") to produce certain documents by November 30, 2011;
WHEREAS, counsel for Lead Plaintiffs and counsel for Wells Fargo have met and conferred about the production deadline set by the Court and have agreed to a brief extension of time within which Wells Fargo may produce the documents as directed by the Court;
WHEREAS, good cause exists for the agreed-upon brief extension of time, including the Thanksgiving holiday and corresponding travel plans and absences of Wells Fargo's outside counsel and staff, the volume of documents at issue (including loan files consisting of over 850,000 pages of documents) and the fact that the loan files to be produced were identified by Lead Plaintiffs only about one month ago;
WHEREAS, the deadlines set out in this stipulation represent Wells Fargo's best estimate of reasonable time frames within which the documents at issue can be produced based on the information currently available to it;
THEREFORE, subject to further revision as may be agreed upon by Lead Plaintiffs and Wells Fargo, the parties hereto stipulate to the following deadlines for production: 1) All requested loan files (approximately 948 total) shall be produced on or before December 2, 2011; 2) The rest of the documents Wells Fargo previously agreed to produce, along with the CQA reports, shall be produced on or before December 9, 2011.
MUNGER, TOLLES & OLSON LLP
MARC T.G. DWORSKY
DAVID H. FRY
KATHLEEN M. McDOWELL
AARON G. LEIDERMAN
Kathleen M. McDowell
Attorneys for Third Party
WELLS FARGO BANK, N.A.
ROBBINS GELLER RUDMAN & DOWD LLP
THOMAS E. EGLER
NATE LINDELL
Thomas E. Egler
Attorneys for Lead Plaintiffs
CITY OF ANN ARBOR EMPLOYEES
RETIREMENT SYSTEM and GREATER
KANSAS CITY LABORERS PENSION FUND
ORDER
Pursuant to the stipulation of Lead Plaintiffs and Wells Fargo, the Court hereby sets the following deadlines for production: 1) All requested loan files (approximately 948 total) shall be produced on or before December 2, 2011; 2) The rest of the documents Wells Fargo previously agreed to produce, along with the CQA reports, shall be produced on or before December 9, 2011.
These dates may be further modified by Court order.
IT IS SO ORDERED AS MODIFIED.
Hon. Nathanael M. Cousins