Rivkin v. JPMorgan Chase Bank, N.A., et al.
Filing
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STIPULATION and ORDER signed by District Judge Troy L. Nunley on 2/18/15. JPMC shall have to and including 3/25/15 to respond to the first amended complaint. (Manzer, C)
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MORGAN, LEWIS & BOCKIUS LLP
Amy M. Spicer (SBN 188399)
One Market, Spear Street Tower
San Francisco, CA 94105-1126
Tel: 415.442.1000
Fax: 415.963.1001
E-mail:
aspicer@morganlewis.com
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: jduffy@morganlewis.com
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/ 25751057.1
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.
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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.
On January 21, 2015, the Parties entered into a further stipulation to
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extend the time for JPMC to respond to the First Amended Complaint in view of
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Plaintiff’s pending request for leave to file a second amended complaint. (Docket
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No. 25.) The Court entered an order approving the Parties’ stipulation on January
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22, 2015. (Docket No. 26.) JPMC’s current deadline to respond to the First
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Amended Complaint is February 19, 2015.
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G.
request for leave to file the second amended complaint.
H.
MORGAN, LEWIS &
BOCKIUS LLP
In view of Plaintiff’s pending request for leave to amend the operative
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ATTORNEYS AT LAW
LOS ANGELES
As of February 17, 2015, the Court has not yet ruled on Plaintiff’s
DB2/ 25751057.1
STIPULATION AND ORDER TO EXTEND
TIME TO RESPOND TO FAC
CASE NO. 14-2662-TLN-EFB
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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 March 25, 2015.
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I.
This is the Parties’ third request for an extension of time to respond to
the First Amended Complaint.
IT IS THEREFOR STIPULATED that JPMC shall have to and including
March 25, 2015 to respond to Plaintiff’s First Amended Complaint.
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Dated: February 17, 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 February 17, 2015)
Pamela M. Schuur
Dated: February 17, 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.
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Dated: 2/18/2015
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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/ 25751057.1
STIPULATION AND ORDER TO EXTEND
TIME TO RESPOND TO FAC
CASE NO. 14-2662-TLN-EFB
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