Filed: Jul. 23, 2019
Latest Update: Jul. 23, 2019
Summary: JOINT STIPULATION TO EXTEND DEFENDANT WELLS FARGO'S TIME TO FILE REPLY IN SUPPORT OF ITS MOTION TO DISMISS PURSUANT TO L.R. 6-2; ORDER HAYWOOD S. GILLIAM, JR. , District Judge . Defendant Wells Fargo Bank, N.A. ("Wells Fargo") and 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 by and through their counsel of record, hereby stipulate as follows: 1.
Summary: JOINT STIPULATION TO EXTEND DEFENDANT WELLS FARGO'S TIME TO FILE REPLY IN SUPPORT OF ITS MOTION TO DISMISS PURSUANT TO L.R. 6-2; ORDER HAYWOOD S. GILLIAM, JR. , District Judge . Defendant Wells Fargo Bank, N.A. ("Wells Fargo") and 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 by and through their counsel of record, hereby stipulate as follows: 1. W..
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JOINT STIPULATION TO EXTEND DEFENDANT WELLS FARGO'S TIME TO FILE REPLY IN SUPPORT OF ITS MOTION TO DISMISS PURSUANT TO L.R. 6-2; ORDER
HAYWOOD S. GILLIAM, JR., District Judge.
Defendant Wells Fargo Bank, N.A. ("Wells Fargo") and 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 by and through their counsel of record, hereby stipulate as follows:
1. WHEREAS, on May 8, 2019, an Order was entered approving a schedule that called for Wells Fargo to file its Motion to Dismiss the initial complaint filed in this matter on June 10, 2019, the Plaintiffs to file their Opposition on July 10, 2019, and Wells Fargo to file its Reply on July 25, 2019 (the "Order");
2. WHEREAS, on June 10, 2019, Wells Fargo filed its Motion to Dismiss Plaintiffs' Complaint (Dkt. 37);
3. WHEREAS, on July 3, 2019, the Parties filed a Joint Stipulation to Extend Time to Respond such that Plaintiffs' deadline to file their Opposition would be extended from July 10, 2019 to July 17, 2019 and Wells Fargo's deadline to file its Reply would be extended from July 25, 2019 to August 1, 2019 (Dkt. 44);
4. WHEREAS, on July 6, 2019, the Court ordered Plaintiffs' deadline to file their Opposition be extended from July 10, 2019 to July 17, 2019 and Wells Fargo's deadline to file its Reply be extended from July 25, 2019 to August 1, 2019 (Dkt. 45);
5. WHEREAS, on July 17, 2019, Plaintiffs filed their Opposition to Defendant Wells Fargo Bank, N.A.'s Motion to Dismiss Plaintiffs' Complaint (Dkt. 46);
6. WHEREAS, on July 19, 2019, the Parties met and conferred and stipulated to extend Defendant Wells Fargo Bank N.A.'s deadline to file its Reply from August 1, 2019 to August 8, 2019;
7. WHEREAS, the hearing on Wells Fargo's Motion to Dismiss is now scheduled for October 24, 2019;
8. WHEREAS, extending the foregoing deadline will not impact any other deadlines in this case.
WHEREFORE, the Parties hereby agree that Wells Fargo's deadline to file a Reply in support of its Motion to Dismiss is extended from August 1, 2019 to August 8, 2019.
DATED: July 22, 2019
McGUIREWOODS LLP
By: /s/ Carolee A. Hoover
Carolee A. Hoover
Attorneys for Defendant WELLS FARGO
BANK, N.A.
DATED: July 22, 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
Attorneys for Plaintiffs, Individually and on behalf of all
others similarly situated.
SIGNATURE ATTESTATION
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, and good cause appearing, it is so ordered.
