Brenes v. Wells Fargo Bank, N.A. et al

Filing 15

ORDER signed by Senior Judge William B. Shubb on 4/11/2018 GRANTING 14 JOINT MOTION for EXTENSION of TIME for defendant Wells Fargo Bank to file Answer by 5/18/2018. (Kirksey Smith, K)

1 MARK D. LONERGAN (State Bar No. 143622)
[e-mail]
2 REBECCA S. SAELAO (State Bar No. 222731)
[e-mail]
3 ALISA A. GIVENTAL (State Bar No. 273551)
[e-mail]
4 SEVERSON & WERSON
A Professional Corporation
5 One Embarcadero Center, Suite 2600
San Francisco, California 94111
6 Telephone: [phone]
Facsimile: [phone]
7
Attorneys for Defendant
8 WELLS FARGO BANK, N.A.
9
10

UNITED STATES DISTRICT COURT

11

EASTERN DISTRICT OF CALIFORNIA

12 CRYSTAL BRENES,

Case No. 2:18-cv-00194-WBS-CKD

13

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

14

Plaintiff,
vs.

15 WELLS FARGO BANK, N.A.; TRANS
UNION, LLC; and EQUIFAX
16 INFORMATION SERVICES, LLC,
17

Complaint Served:
Response Deadline:
First Extended Deadline:
New Response Deadline:

February 21, 2018
March 14, 2018
April 11, 2018
May 18, 2018

Defendants.

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19

Pursuant to United States District Court, Eastern District of California, Civil Local Rule

20 144(a), which requires Court approval for any extension to respond to the initial complaint beyond
21 28 days, plaintiff Crystal Brenes (“Plaintiff”) and defendant Wells Fargo Bank, N.A.
22 (“Defendant”), hereby jointly move for an extension for Defendant to file its responsive pleading
23 based on the following facts:
24

1.

Plaintiff served the Complaint on February 21, 2018;

25

2.

Defendant’s deadline to respond to the Complaint was March 14, 2018;

26

3.

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

27 April 11, 2018;
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4.

Plaintiff and Defendant are engaged in settlement discussions and believe that they

07685.1993/11162229.1

2:18-cv-00194-WBS-CKD
JOINT MOTION TO EXTEND DEADLINE TO RESPOND
TO COMPLAINT AND [PROPOSED] ORDER

1

1 can resolve their dispute if an additional 37-day extension is granted by the Court;
2

5.

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

3 Defendant’s deadline to respond to the Complaint to May 18, 2018.
4
5 DATED: April 11, 2018
6

REZNIK LAW OFFICE
By:

/s/ Gemma L. Mondala
Gemma L. Mondala

7

Attorneys for Plaintiff CRYSTAL BRENES

8
9
DATED: April 11, 2018

SEVERSON & WERSON
A Professional Corporation

10
11

By:

/s/ Alisa A. Givental
Alisa A. Givental

12

Attorneys for Defendant WELLS FARGO BANK, N.A.

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14
15
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Pursuant to Local Rule 5-1(i)(3), I – Alisa A. Givental – attest that concurrence in the
filing of this document has been obtained from Gemma L. Mondala. /s/ Alisa A. Givental

17
18

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

19 N.A., and good cause appearing, the deadline for Defendant to respond to Plaintiff’s complaint is
20 hereby extended to May 18, 2018. No other deadlines shall be affected by this Order.
21

IT IS SO ORDERED.

22 Dated: April 11, 2018
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25
26
27
28
07685.1993/11162229.1

2:18-cv-00194-WBS-CKD
JOINT MOTION TO EXTEND DEADLINE TO RESPOND
TO COMPLAINT AND [PROPOSED] ORDER

2