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Ginzkey v. National Securities Corp.

United States District Court, W.D. Washington, Seattle

January 15, 2020

JAMES GINZKEY, RICHARD FITZGERALD, CHARLES CERF, BARRY DONNER, and on behalf of the class members described below, Plaintiffs,
v.
NATIONAL SECURITIES CORPORATION, a Washington Corporation, Defendant.

          David P. Neuman, WSBA #48176 ISRAELS NEUMAN PLC, Alexander N. Loftus, pro hac vice Joseph Wojciechowski, pro hac vice STOLTMANN LAW OFFICES, Joshua B. Kons, Esq., pro hac vice LAW OFFICES OF JOSHUA B. KONS, LLC Attorneys for Plaintiffs James Ginzkey, Richard Fitzgerald, Charles Cerf, and Barry Donner

          Douglas W. Greene, WSBA #22844 James R. Morrison, WSBA #43043 BAKER & HOSTETLER, Fred Knopf, pro hac vice pending Chad Weaver, pro hac vice pending Elizabeth Fellmeth, pro hac vice K. Nikki Sachdeva, pro hac vice pending FREEMAN MATHIS & GARY LLP Attorneys for Defendant National Securities Corporation

          STIPULATED MOTION AND ORDER REVISING SCHEDULING ORDER REGARDING CLASS CERTIFICATION

          RICARDO S. MARTINEZ CHIEF UNITED STATES DISTRICT JUDGE

         Plaintiffs James Ginzkey, Richard Fitzgerald, Charles Cerf, and Barry Donner (collectively, “Plaintiffs”) and Defendant National Securities Corporation (“Defendant”) (collectively, the “Parties”), by and through their undersigned attorneys, hereby submit this Stipulated Motion to Revise the Scheduling Order Regarding Class Certification in this case.

         IT IS HEREBY STIPULATED:

         WHEREAS, Plaintiffs filed the Complaint in this action on December 10, 2018 (ECF No. 1);

         WHEREAS, the Court issued an Order on October 7, 2019 on the Parties' prior Stipulated Motion to Revise the Scheduling Order (ECF No. 35). The Court set a deadline for the Parties to complete discovery on class certification by February 3, 2020. The Court set a deadline for Plaintiffs to file a motion for class certification by March 2, 2020;

         WHEREAS, the Parties are conducting discovery on class certification through written discovery requests, document productions, and depositions. In order to respond to discovery requests, Defendants are in the process of reviewing over 140, 000 pages of documents and anticipate the need to collect additional documents. The Parties also need to take at least five depositions prior to briefing class certification issues; WHEREAS, given the complexity of the class certification issues, the volume of document discovery to be conducted, and the witnesses' and counsel's availability for depositions, the Parties anticipate that they will require additional time to complete discovery regarding class certification;

         WHEREAS, should the Court grant the Parties' request to revise the Scheduling Order, the Parties have agreed to conduct the necessary depositions pursuant to the following schedule:

• Rule 30(b)(6) Deposition of Defendant on February 25, 2020 in New York, NY;
• Deposition of Plaintiffs James Ginzkey and Richard Fitzgerald on March 2, 2020 and March 3, 2020 in Chicago, IL;
• Deposition of Plaintiff Barry Donner on March 11, 2020, in Orange County, CA;
• Deposition of Plaintiff Charles Cerf on March 23, 2020 in Washington, DC;

         WHEREAS, there is good cause to continue the deadlines for class certification discovery and briefing given the amount of time required to conduct all necessary discovery on class certification issues. In particular, the Parties anticipate that they will need approximately 90 additional days to collect and exchange documents, prepare for ...


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