Rivkin v. JPMorgan Chase Bank, N.A., et al.

Filing 26

STIPULATION and ORDER 25 for extension of time signed by District Judge Troy L. Nunley on 1/21/2015. Defendant JPMorgan Chase has to and including 2/19/2015 to respond to plaintiff's First Amended Complaint. (Marciel, M)

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MORGAN, LEWIS & BOCKIUS LLP
Amy M. Spicer (SBN 188399)
One Market, Spear Street Tower
San Francisco, CA 94105-1126
Tel: [phone]
Fax: [phone]
E-mail:
[e-mail]
MORGAN, LEWIS & BOCKIUS LLP
Joseph Duffy (SBN 241854)
300 South Grand Avenue
Twenty-Second Floor
Los Angeles, CA 90071-3132
Tel:
213.612.2500
Fax:
213.612.2501
Email: [e-mail]
Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.

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UNITED STATES DISTRICT COURT

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FOR THE EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO
DIVISION

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VLADIMIR RIVKIN,

Case No. 14-2662-TLN-EFB

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vs.

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STIPULATION TO EXTEND
TIME FOR DEFENDANT
JPMORGAN CHASE BANK, N.A.
TO RESPOND TO PLAINTIFF’S
FIRST AMENDED COMPLAINT
AND ORDER

Plaintiff,

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JPMORGAN CHASE BANK, N.A., a
New York association; FAY
SERVICING LLC, a Delaware limited
liability company; ALBERTELLI LAW
PARTNERS CALIFORNIA, PA, a
California corporation,, and DOES 1
through 10,

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Defendants.

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MORGAN, LEWIS &
BOCKIUS LLP
ATTORNEYS AT LAW

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LOS ANGELES

DB2/ 25713314.2

STIPULATION AND ORDER TO EXTEND
TIME TO RESPOND TO FAC
CASE NO. 14-2662-TLN-EFB

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Plaintiff Vladimir Rivkin (“Plaintiff”) and Defendant JPMorgan Chase Bank,

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N.A. (“JPMC” and with Plaintiff, the “Parties”), hereby enter into this Stipulation

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to Extend Time for Defendant to Respond to Plaintiff’s First Amended Complaint

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with reference to the following facts:
RECITALS

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A.

On or about October 16, 2014, Plaintiff commenced an action in the

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Superior Court for the County of Nevada entitled Rivkin v. JPMorgan Chase Bank,

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N.A., et al., Case Number TCU14-5931 (the “State Court Action”).

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B.

On or around October 23, 2014, Plaintiff served the Summons and

First Amended Complaint on JPMC.
C.

On November 14, 2014, JPMC timely removed the State Court Action

to this Court.
D.

On November 25, 2014, the Parties entered into a stipulation to extend

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the time for JPMC to respond to the First Amended Complaint to allow the Plaintiff

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and co-defendant Fay Servicing LLC to engage in discussions regarding the then

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pending Trustee’s Sale and in view of the possibility of Plaintiff filing a second

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amended complaint. JPMC’s current deadline to respond to the First Amended

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Complaint is January 22, 2015.

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E.

On January 8, 2015, Plaintiff filed a request for leave to file a second

amended complaint. (Docket No. 21.)
F.

As of January 20, 2015, the Court has not yet ruled on Plaintiff’s

request for leave to file the second amended complaint.
G.

In view of Plaintiff’s pending request for leave to amend the operative

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complaint, the Parties have agreed to extend the time for JPMC to respond to

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Plaintiff’s First Amended Complaint to and including February 19, 2015.

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F.

to the First Amended Complaint.
IT IS THEREFOR STIPULATED that JPMC shall have to and including

MORGAN, LEWIS &
BOCKIUS LLP

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ATTORNEYS AT LAW
LOS ANGELES

This is the Parties’ second request for an extension of time to respond

DB2/ 25713314.2

STIPULATION AND ORDER TO EXTEND
TIME TO RESPOND TO FAC
CASE NO. 14-2662-TLN-EFB

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February 19, 2015 to respond to Plaintiff’s First Amended Complaint.

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Dated: January 21, 2015

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FRANZ LAW
By:

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Attorneys for Plaintiff
VLADIMIR RIVKIN

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/s/ Pamela M. Schuur (as authorized
on January 21, 2015)
Pamela M. Schuur

Dated: January 20, 2015

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MORGAN, LEWIS & BOCKIUS LLP
By: /s/ Amy M. Spicer
Amy M. Spicer

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Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.

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ORDER

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IT IS SO ORDERED.
Dated: January 21, 2015

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Troy L. Nunley
United States District Judge

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MORGAN, LEWIS &
BOCKIUS LLP

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ATTORNEYS AT LAW
LOS ANGELES

DB2/ 25713314.2

STIPULATION AND ORDER TO EXTEND
TIME TO RESPOND TO FAC
CASE NO. 14-2662-TLN-EFB