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

Filing 28

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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1 2 3 4 5 6 7 8 9 10 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. 11 12 UNITED STATES DISTRICT COURT 13 14 FOR THE EASTERN DISTRICT OF CALIFORNIA – SACRAMENTO DIVISION 15 16 VLADIMIR RIVKIN, Case No. 14-2662-TLN-EFB 17 vs. 19 20 21 22 23 STIPULATION TO EXTEND TIME FOR DEFENDANT JPMORGAN CHASE BANK, N.A. TO RESPOND TO PLAINTIFF’S FIRST AMENDED COMPLAINT AND ORDER Plaintiff, 18 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, 24 Defendants. 25 26 27 28 MORGAN, LEWIS & BOCKIUS LLP ATTORNEYS AT LAW 1 LOS ANGELES DB2/ 25751057.1 STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO FAC CASE NO. 14-2662-TLN-EFB 1 Plaintiff Vladimir Rivkin (“Plaintiff”) and Defendant JPMorgan Chase Bank, 2 N.A. (“JPMC” and with Plaintiff, the “Parties”), hereby enter into this Stipulation 3 to Extend Time for Defendant to Respond to Plaintiff’s First Amended Complaint 4 with reference to the following facts: RECITALS 5 6 A. On or about October 16, 2014, Plaintiff commenced an action in the 7 Superior Court for the County of Nevada entitled Rivkin v. JPMorgan Chase Bank, 8 N.A., et al., Case Number TCU14-5931 (the “State Court Action”). 9 10 11 12 13 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 14 the time for JPMC to respond to the First Amended Complaint to allow the Plaintiff 15 and co-defendant Fay Servicing LLC to engage in discussions regarding the then 16 pending Trustee’s Sale and in view of the possibility of Plaintiff filing a second 17 amended complaint. 18 19 20 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 21 extend the time for JPMC to respond to the First Amended Complaint in view of 22 Plaintiff’s pending request for leave to file a second amended complaint. (Docket 23 No. 25.) The Court entered an order approving the Parties’ stipulation on January 24 22, 2015. (Docket No. 26.) JPMC’s current deadline to respond to the First 25 Amended Complaint is February 19, 2015. 26 27 28 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 2 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 1 complaint, the Parties have agreed to extend the time for JPMC to respond to 2 Plaintiff’s First Amended Complaint to and including March 25, 2015. 3 4 5 6 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. 7 8 Dated: February 17, 2015 9 FRANZ LAW By: 10 11 Attorneys for Plaintiff VLADIMIR RIVKIN 12 13 /s/ Pamela M. Schuur (as authorized on February 17, 2015) Pamela M. Schuur Dated: February 17, 2015 14 MORGAN, LEWIS & BOCKIUS LLP By: /s/ Amy M. Spicer Amy M. Spicer 15 Attorneys for Defendant JPMORGAN CHASE BANK, N.A. 16 17 18 19 20 ORDER 21 22 IT IS SO ORDERED. 23 24 Dated: 2/18/2015 25 Troy L. Nunley United States District Judge 26 27 28 MORGAN, LEWIS & BOCKIUS LLP 3 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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