Ortega v. JPMorgan Chase Bank

Filing 6

STIPULATION and ORDER to Extend Time for Defendant JP Morgan Chase Bank, N.A. to Respond to Complaint signed by Magistrate Judge Erica P. Grosjean on 5/16/2017. The Court GRANTS the stipulation, as follows: Chase shall answer, move, or otherwise respond to Plaintiff's complaint on or before June 23, 2017. (Valdez, E)

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Joseph E. Addiego III (CA SBN 169522)
John D. Freed (CA SBN 261518)
DAVIS WRIGHT TREMAINE LLP
505 Montgomery Street, Suite 800
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]
Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.

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IN THE UNITED STATES DISTRICT COURT

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THE EASTERN DISTRICT OF CALIFORNIA

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PABLO ORTEGA,
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Plaintiff,
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v.
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JPMORGAN CHASE BANK, N.A., et al.,
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Defendants.
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Case No. 17-cv-00531-DAD-EPG
STIPULATION AND ORDER TO
EXTEND TIME FOR DEFENDANT JP
MORGAN CHASE BANK, N.A. TO
RESPOND TO COMPLAINT
[Civ. L.R. 144(a)]
Action Removed April 14, 2017

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WHEREAS, on April 14, 2017, Defendant JPMorgan Chase Bank, N.A. (“Chase”)
removed this matter from state court; and
WHEREAS, pursuant to Federal Rule of Civil Procedure 81, the original deadline of Chase
to respond to the Complaint would be April 21, 2017; and
WHEREAS, the parties have begun a settlement dialogue and seek additional time to

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resolve this matter informally without the need for active litigation, including time for Plaintiff to

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apply with Chase for loan modification.

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NOW THEREFORE, Plaintiff and Chase HEREBY STIPULATE AND AGREE AS
FOLLOWS, subject to the Court’s approval:
The deadline for Chase to answer, move, or otherwise respond to Plaintiff’s Complaint
shall be extended up to and including June 23, 2017.
IT IS SO STIPULATED.
DATED April 17, 2017

DAVIS WRIGHT TREMAINE LLP
Joseph E. Addiego, III
John D. Freed

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By: /s/ John D. Freed
John D. Freed
Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.

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MELLEN LAW FIRM
Jessica Galletta

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By:/s/ Jessica Galletta______________
Jessica Galletta

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Attorneys for Plaintiff

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ORDER

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Presently before the Court is a stipulation between Plaintiff and Defendant JPMorgan

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Chase Bank, N.A. (“Chase”) to extend the time for Chase to answer, move, or otherwise respond

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to Plaintiff’s complaint up to and including June 23, 2017.

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Good cause appearing therefor, the Court GRANTS the stipulation, as follows: Chase shall
answer, move, or otherwise respond to Plaintiff’s complaint on or before June 23, 2017.

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IT IS SO ORDERED.
Dated:

May 16, 2017

/s/
UNITED STATES MAGISTRATE JUDGE