Stipulation And [Proposed] Order To Vacate Stay And To Set Schedule For Further Proceedings 

Case No. C08-00369 TEH 

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BONNETT, FAIRBOURN, FRIEDMAN 

& BALINT, P.C. 

Andrew S. Friedman (Admitted Pro Hac Vice)

Wendy J. Harrison (CA SBN 151090) 

2901 North Central Avenue, Suite 1000 

Phoenix, Arizona 85012 

Tel: (602) 274-1100 

Fax: (602) 274-1199 

E-mail: afriedman@bffb.com 

 wharrison@bffb.com 

RODDY KLEIN & RYAN 

Gary Klein (Admitted Pro Hac Vice)

Shennan Kavanagh (To be admitted Pro Hac Vice)

727 Atlantic Avenue 

Boston, MA 02111-2810 

Tel: (617) 357-5500, ext. 15 

Fax: (617) 357-5030 

[Additional counsel listed on signature page]

Attorneys for Plaintiffs 

and the Proposed Class 

UNITED STATES DISTRICT COURT 

NORTHERN DISTRICT OF CALIFORNIA 

SAN FRANCISCO DIVISION 

ANA RAMIREZ and ISMAEL RAMIREZ, 

on behalf of themselves and all others 

similarly situated, 

 Plaintiffs, 

 vs. 

GREENPOINT MORTGAGE FUNDING, 

INC.,

 Defendant. 

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No. C 08-00369 TEH 

CLASS ACTION

STIPULATION AND [PROPOSED] 

ORDER TO VACATE STAY AND TO 

SET SCHEDULE FOR FURTHER 

PROCEEDINGS 

Date: March 8, 2010 

Time: 10:00 am 

Court: Honorable Thelton E. Henderson 

Dept: Courtroom 12, 19th Floor 

Case 3:08-cv-00369-TEH Document 155 Filed 02/12/10 Page 1 of 5
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Stipulation And [Proposed] Order To Vacate Stay And To Set Schedule For Further Proceedings 

Case No. C08-00369 TEH 

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WHEREAS the parties have agreed not to seek approval of the Stipulation and 

Agreement of Settlement previously lodged with the Court [Docket No. 143]; and 

WHEREAS plaintiffs have filed an unopposed motion to withdraw from that 

agreement; 

WHEREAS the parties seek a schedule for proceedings on class certification and other 

aspects of litigation of this matter; 

It is hereby stipulated by plaintiffs Ana Ramirez, Ismael Ramirez, and 

Jorge Salazar and defendant GreenPoint Mortgage Funding, Inc., through their respective 

counsel, as follow: 

1. The stay of the litigation schedule entered on September 11, 2009 [Docket No. 

139] shall be vacated. 

2. The Proposed Schedule For Further Proceedings attached hereto as Exhibit A 

shall be adopted by the Court.

DATED: February 10, 2010 RODDY KLEIN & RYAN 

CHAVEZ & GERTLER LLP

MILLER LAW LLC 

NATIONAL CONSUMER LAW CENTER 

BONNETT, FAIRBOURN, FRIEDMAN & 

BALINT, P.C. 

/s/ Gary Klein 

Gary Klein 

Attorneys for Plaintiffs 

DATED: February 10, 2010 SKADDEN, ARPS, SLATE, MEAGHER & 

FLOM LLP 

/s/ Anand S. Raman 

Anand S. Raman (admitted pro hac vice)

1440 New York Avenue, N.W. 

Washington, D.C. 20005 

Telephone: 202-371-7000 

Case 3:08-cv-00369-TEH Document 155 Filed 02/12/10 Page 2 of 5
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Stipulation And [Proposed] Order To Vacate Stay And To Set Schedule For Further Proceedings 

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Facsimile: 202-393-5760 

Raoul D. Kennedy (CA SBN 40892) 

Four Embarcadero Center, Suite 3800 

San Francisco, California 93111-3133 

Telephone: (415) 984-6400 

Facsimile: 415-984-2698 

Attorneys for Defendant 

Additional counsel for plaintiffs:

MILLER LAW LLC 

Marvin A. Miller 

Lori A. Fanning (To be admitted Pro Hac 

Vice)

115 South LaSalle Street, Suite 2910 

Chicago, IL 60603 

Tel: (312) 332-3400 

NATIONAL CONSUMER LAW CENTER 

Stuart T. Rossman (To be admitted Pro Hac 

Vice)

Charles Delbaum (To be admitted Pro Hac 

Vice)

77 Summer Street, 10th Flr. 

Boston, MA 02141 

Tel: (617) 542-8010 

Fax: (617) 542-8028 

CHAVEZ & GERTLER LLP 

Mark A. Chavez (CA SBN 90858) 

Nance F. Becker (CA SBN 99292) 

Dan Gildor (CA SBN 223027) 

42 Miller Avenue 

Mill Valley, California 94941 

Tel: (415) 381-5599 

Fax: (415) 381-5572 

PURSUANT TO STIPULATION, IT IS SO ORDERED. 

DATED: ____________, 2010 ________________________________ 

The Honorable Thelton E. Henderson 

United States District Court Judge

February 11

UNITED STATES DISTRICT COURT

NORTHERN DISTRICT OF CALIFORN

I

A

IT IS SO ORDERED

Judge Thelton E. Henderson

Case 3:08-cv-00369-TEH Document 155 Filed 02/12/10 Page 3 of 5
EXHIBIT A

Case 3:08-cv-00369-TEH Document 155 Filed 02/12/10 Page 4 of 5
EXHIBIT A – Proposed Schedule 

Pretrial or Trial Event Requested Deadline 

Motion for Class Certification March 1, 2010 

Response to Motion for Class Certification April 15, 2010 

Plaintiffs’ Reply on Motion for Class 

Certification 

May 17, 2010 

Expert Discovery on Merits Parties meet and confer 

following resolution of class 

certification motion 

Last day for hand-serving motions and filings 

(other than Motions in Limine) 

Parties meet and confer 

following resolution of class 

certification motion 

Non-Expert Discovery Cut-Off Date Parties meet and confer 

following resolution of class 

certification motion 

Parties to meet and confer to prepare joint final 

pretrial conference statement and proposed 

order and coordinated submission of trial 

exhibits and other material 

Parties meet and confer 

following resolution of class 

certification motion 

Filing Joint Pretrial Conference Statement and 

Proposed Order 

Parties meet and confer 

following resolution of class 

certification motion 

Lodging exhibits and other trial materials Parties meet and confer 

following resolution of class 

certification motion 

Last day to serve and file briefs on disputed 

issues of law, including procedural and 

evidentiary issues

Parties meet and confer 

following resolution of class 

certification motion 

Serve and file requested voir dire, jury 

instructions and forms of verdict 

Parties meet and confer 

following resolution of class 

certification motion 

Serve and file statements designating deposition 

excerpts, form interrogatory answers and 

responses to requests for admission to be offered 

at trial other than for impeachment or rebuttal 

Parties meet and confer 

following resolution of class 

certification motion 

Last day to meet and confer regarding 

objections to evidence 

Parties meet and confer 

following resolution of class 

certification motion 

Final Pretrial Conference and Hearing on 

Motions in Limine 

Parties meet and confer 

following resolution of class 

certification motion 

Trial Date Parties meet and confer 

following resolution of class 

certification motion 

Case 3:08-cv-00369-TEH Document 155 Filed 02/12/10 Page 5 of 5