Miller v. Equifax, Inc. et al

Filing 27

STIPULATION and ORDER signed by District Judge John A. Mendez on 5/2/2018 ORDERING the deadline for Defendant to respond to Plaintiffs complaint is hereby EXTENDED to 6/1/2018. No other deadlines shall be affected by this Order. (Washington, S)

1 MARK D. LONERGAN (State Bar No. 143622)
REBECCA S. SAELAO (State Bar No. 222731)
2 ALISA A. GIVENTAL (State Bar No. 273551)
SEVERSON & WERSON
3 A Professional Corporation
One Embarcadero Center, Suite 2600
4 San Francisco, California 94111
Telephone: [phone]
5 Facsimile: [phone]
6 ROCHELLE L. SMITH (State Bar No. 316225)
SEVERSON & WERSON
7 A Professional Corporation
The Atrium
8 19100 Von Karman Avenue, Suite 700
Irvine, California 92612
9 Telephone: [phone]
Facsimile: [phone]
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Attorneys for Defendants
11 WELLS FARGO BANK, N.A.
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UNITED STATES DISTRICT COURT
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EASTERN DISTRICT OF CALIFORNIA, SACRAMENTO DIVISION — SACRAMENTO
DIVISION

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16 CRYSTAL MILLER,
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Case No. 2:18-CV-00126-JAM-CKD
Hon. John A. Mendez

Plaintiff,
vs.

19 EXPERIAN INFORMATION SOLUTIONS,
INC,; EQUIFAX, INC.; BANK OF
20 AMERICA, N.A.; HARLEY DAVIDSON
CREDIT CORPORATION, WELLS FARGO
21 BANK, N.A., AND DOES 1 THROUGH 100
INCLUSIVE,
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Defendant.
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JOINT MOTION TO EXTEND
DEADLINE TO RESPOND TO
COMPLAINT AND ORDER
Complaint Served:
Orig. Response Deadline:
New Response Deadline:
New. Response Deadline:
Prop Response Deadline:

February 12, 2018
March 5, 2018
April 2, 2018
May 2, 2018
June 1, 2018

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Pursuant to United States District Court, Eastern District of California, Civil Local Rule
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144(a), which requires Court approval for any extension to respond to the initial complaint beyond
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28 days, plaintiff Crystal Miller (“Plaintiff”) and Defendant Wells Fargo Bank, N.A.
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(“Defendant”), hereby jointly move for an extension for Defendant to file its responsive pleading
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07685.1986/11197945.1

JOINT MOTION TO EXTEND DEADLINE TO RESPOND TO COMPLAINT AND [PROPOSED] ORDER

1 based on the following facts:
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1.

Plaintiff served the Complaint on February 12, 2018;

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2.

Defendant’s deadline to respond to the Complaint was March 5, 2018;

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3.

Plaintiff and Defendant entered into a stipulation to postpone the response deadline

5 to April 2, 2018;
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4.

Plaintiff and Defendant are engaged in settlement discussions and jointly moved to

7 extend the response deadline to May 2, 2018 , the request was granted;
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5.

Plaintiff and Defendant are continuing settlement discussions and believe that they

9 can resolve their dispute if an additional 30 day extension is granted by the Court.
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6.

Plaintiff and Defendant therefore move jointly to extend for the third time

11 Defendant’s deadline to respond to the Complaint to June 1, 2018.
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DATED: May 2, 2018

SAGARIA LAW, P.C.

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By:

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/s/ Elliott W. Gale
Elliot W. Gale

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Attorneys for Plaintiff CRYSTAL MILLER
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18 DATED: May 2, 2018
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SEVERSON & WERSON
A Professional Corporation

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By:

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/s/ Rochelle L.Smith
Rochelle L. Smith

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Attorneys for Defendant WELLS FARGO BANK,
N.A.

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I, Rochelle L. Smith, am the ECF user whose identification and password are being used to
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file this Stipulation. I hereby attest that Elliot Gale has concurred in this filing.
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By:

/s/ Rochelle L. Smith

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07685.1986/11197945.1

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JOINT MOTION TO EXTEND DEADLINE TO RESPOND TO COMPLAINT AND [PROPOSED] ORDER

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ORDER
Pursuant to the joint motion of plaintiff Crystal Miller and defendant Wells Fargo Bank,

3 N.A., and good cause appearing, the deadline for Defendant to respond to Plaintiff’s complaint is
4 hereby extended to June 1, 2018. No other deadlines shall be affected by this Order.
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IT IS SO ORDERED.

6 DATED: May 2, 2018
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/s/ John A. Mendez________
HON. JOHN A MENDEZ.

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07685.1986/11197945.1

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JOINT MOTION TO EXTEND DEADLINE TO RESPOND TO COMPLAINT AND [PROPOSED] ORDER