Opinion
Case No. 3:11-cv-01320 EDL
10-18-2011
TINA M. UBALDI, on behalf of herself and all others similarly situated, Plaintiff, v. SLM CORPORATION, d/b/a SALLIE MAE, INC., d/b/a SALLIE MAE SERVICING, a Delaware corporation Defendant.
Janet Lindner Spielberg (SBN 221926) LAW OFFICES OF JANET LINDNER SPIELBERG Michael D. Braun (SBN 167416) BRAUN LAW GROUP, P.C. ATTORNEYS FOR PLAINTIFF Joseph N. Kravec, Jr. (admitted pro hac ) Edward J. Feinstein ( pro hac to be filed) STEMBER FEINSTEIN DOYLE & PAYNE, LLC William J. Genego (SBN 103224) NASATIR, HIRSCH, PODBERESKY KHERO & GENEGO STROOCK & STROOCK & LAVAN LLP JULIA B. STRICKLAND LISA M. SIMONETTI DAVID W. MOON David W. Moon Attorneys for Defendant SLM Corporation
Janet Lindner Spielberg (SBN 221926)
LAW OFFICES OF JANET LINDNER
SPIELBERG
Michael D. Braun (SBN 167416)
BRAUN LAW GROUP, P.C.
ATTORNEYS FOR PLAINTIFF
Joseph N. Kravec, Jr. (admitted pro hac)
Edward J. Feinstein (pro hac to be filed)
STEMBER FEINSTEIN DOYLE
& PAYNE, LLC
William J. Genego (SBN 103224)
NASATIR, HIRSCH, PODBERESKY
KHERO & GENEGO
STIPULATION AND [PROPOSED] ORDER CONTINUING HEARING AND BRIEFING SCHEDULE ON MOTION TO DISMISS AS MODIFIED
WHEREAS, on October 7, 2011, Defendant SLM Corporation filed a Motion to Dismiss Plaintiff's First Amended Complaint for failure to state a claim pursuant to Fed.R.Civ.P. 12(b)(6), which is set for hearing on November 29, 2011;
WHEREAS, due to scheduling conflicts with the current hearing date and briefing schedule, the Parties have agreed to continue the hearing on the Motion to Dismiss and to adjust the briefing schedule accordingly;
WHEREAS, there have been two prior extensions of time granting Defendant additional time to respond to Plaintiff's Complaint (Doc. 8), and continuing the hearing on Defendant's motion to dismiss and granting the Parties additional time to file responsive and reply briefs (Doc. 22); and
WHEREAS, this Stipulation is made in good faith and not for purposes of delay.
IT IS HEREBY STIPULATED by and between the Parties, through their respective counsel of record, as follows:
(a) The hearing on the Motion to Dismiss shall be continued to December 13, 2011 at 2:00 p.m. in Courtroom E;
(b) Plaintiff's Opposition to the Motion shall be filed and served by November 4, 2011; and
(c) Defendant's Reply to Plaintiff's Opposition shall be filed and served by November 29, 2011.
LAW OFFICE OF JANET LINDNER SPIELBERG
Janet Lindner Spielberg
Attorneys for Plaintiff
STROOCK & STROOCK & LAVAN LLP
JULIA B. STRICKLAND LISA M. SIMONETTI
DAVID W. MOON
David W. Moon
Attorneys for Defendant SLM Corporation
[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED.
The Honorable Elizabeth D. Laporte