Filed: May 08, 2019
Latest Update: May 08, 2019
Summary: JOINT STIPULATION TO EXTEND TIME TO RESPOND AND BRIEFING SCHEDULE ON MOTION TO DISMISS PURSUANT TO L.R. 6-1 AND ORDER HAYWOOD S. GILLIAM, JR. , District Judge . Plaintiffs Annie Chang, Tiger Chang Investments, LLC, Asians Investing in Real Estate, LLC, Melanie Gonzales, Gary Gonzales, and G&M You-Niques Property LLC (collectively, "Plaintiffs") and Defendant Wells Fargo Bank, N.A. ("Wells Fargo"), and by and through their counsel of record, hereby stipulate as follows: 1. WHEREAS, the init
Summary: JOINT STIPULATION TO EXTEND TIME TO RESPOND AND BRIEFING SCHEDULE ON MOTION TO DISMISS PURSUANT TO L.R. 6-1 AND ORDER HAYWOOD S. GILLIAM, JR. , District Judge . Plaintiffs Annie Chang, Tiger Chang Investments, LLC, Asians Investing in Real Estate, LLC, Melanie Gonzales, Gary Gonzales, and G&M You-Niques Property LLC (collectively, "Plaintiffs") and Defendant Wells Fargo Bank, N.A. ("Wells Fargo"), and by and through their counsel of record, hereby stipulate as follows: 1. WHEREAS, the initi..
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JOINT STIPULATION TO EXTEND TIME TO RESPOND AND BRIEFING SCHEDULE ON MOTION TO DISMISS PURSUANT TO L.R. 6-1 AND ORDER
HAYWOOD S. GILLIAM, JR., District Judge.
Plaintiffs Annie Chang, Tiger Chang Investments, LLC, Asians Investing in Real Estate, LLC, Melanie Gonzales, Gary Gonzales, and G&M You-Niques Property LLC (collectively, "Plaintiffs") and Defendant Wells Fargo Bank, N.A. ("Wells Fargo"), and by and through their counsel of record, hereby stipulate as follows:
1. WHEREAS, the initial Complaint in this matter was filed on April 12, 2019, in the United State District Court, Northern District of California (Dkt. 1).
2. WHEREAS, this case has been assigned to Judge Haywood S. Gilliam, Jr. (Dkt. 15).
3. WHEREAS, on April 18, 2019, Wells Fargo was served with the Summons and Complaint (Dkt. 21).
4. WHEREAS, pursuant to Federal Rule of Civil Procedure 12(a), Wells Fargo's responsive pleading is due twenty-one (21) days after being served with the summons and complaint, or May 9, 2019.
5. WHEREAS, the Parties met and conferred on May 3, 2019 and have agreed to the following briefing schedule with respect to Wells Fargo's anticipated Motion to Dismiss:
Date Pleading
June 10, 2019 Wells Fargo's Motion to Dismiss to be filed
July 10, 2019 Plaintiffs' Opposition Deadline
July 25, 2019 Wells Fargo's Reply Deadline
6. WHEREAS, extending the foregoing deadlines will not impact any other deadlines in this case.
7. WHEREAS, the parties have not previously requested that any other deadlines be extended.
WHEREFORE, the Parties hereby agree that the time for Wells Fargo to respond to the Complaint is extended to June 10, 2019, Plaintiffs' deadline to file an Opposition to Wells Fargo's Motion to Dismiss is July 10, 2019 and Wells Fargo's deadline to file a Reply is July 25, 2019.
DATED: May 7, 2019 MCGUIREWOODS LLP
By: /s/ Carolee A. Hoover
Carolee A. Hoover
Attorneys for Defendant WELLS FARGO
BANK, N.A.
DATED: May 7, 2019 GOLMAN SCARRLATO & PENNY P.C.
By: /s/ Mark S. Goldman
Mark S. Goldman
Mark S. Goldman (Pro Hac Vice)
Paul J. Scarlato (Pro Hac Vice)
Attorneys for Plaintiffs
8 Tower Bridge, Suite 1025
161 Washington Street
Conshohocken, PA 19428
Telephone (484)342-0700
goldman@lawgsp.com
Scalato@lawgsp.com
Eve H. Cervantez
ALTSHULER BERZON LLP
117 Post Street, Suite 300
San Francisco, CA 94108
Tel: (415) 421-7151
Facsimile: (415) 362-8064
Alan L. Rosca (Pro Hac Vice)
GOLMAN SCARLATO & PENNEY P.C.
23250 Chagrin Blvd., Suite 100
Beachwood, OH 44122
Telephone: (484)342-0700
rosca@lawgsp.com
Jonathan Garner (Pro Hac Vice)
Alfred L. Fatale III (Pro Hac Vice)
Ross M. Kamhi (Pro Hac Vice)
LABATON SUCHAROW LLP
140 Broadway
New York, NY 10005
Telephone: (212) 907-0700
Facsimile (212) 818-0477
jgardner@labaton.com
afatale@labaton.com
rkamhi@labaton.com
I attest that all signatories listed above, and on whose behalf this Stipulation is submitted, have concurred in and authorized the filing of the Stipulation.
/s/ Carolee A. Hoover
Carolee A. Hoover
ORDER
Pursuant to the Joint Stipulation Regarding Extension to Respond and Briefing Schedule on Motion to Dismiss Pursuant to L.R. 6-1 filed by the parties, and for good cause, IT IS SO ORDERED.
