Jordan v. Paul Financial, LLC

Filing 186

ORDER granting extension. Signed by Judge Illston on 4/23/09. (ts, COURT STAFF) (Filed on 4/24/2009)

Case 3:07-cv-04496-SI

Document 185

Filed 04/22/2009

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LEE A. WEISS (admitted pro hac vice) [e-mail] BROWNE WOODS GEORGE LLP 49 West 37th Street, 15th Floor New York, New York 10018 Telephone: [phone] Facsimile: [phone] Attorneys for Plaintiff and all others similarly situated IRENE C. FREIDEL (admitted pro hac vice) [e-mail] K&L GATES LLP State Street Financial Center One Lincoln Street Boston, MA 02111 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant Paul Financial LLC

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JOINT STIPULATION TO ENLARGE TIME FOR DEFENDANTS TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF S OBJECTIONS TO, AND NOTICES OF INTENTION TO MOVE TO STRIKE PORTIONS OF THE DECLARATION OF FERNANDO ACEBEDO, DENNIS TUSSEY AND RUSSELL NG
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UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION GREGORY M. JORDAN, individually and behalf of all others similarly situated, Plaintiff, vs. PAUL FINANCIAL LLC, LUMINENT MORTGAGE CAPITAL, INC., LUMINENT MORTGAGE TRUST 2006-2, HSBC NATIONAL ASSOCIATION, and DOES 1 through 10, inclusive, Defendants. Case No. CV07-04496-SI JOINT STIPULATION TO ENLARGE TIME FOR DEFENDANTS TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF S OBJECTIONS TO, AND NOTICES OF INTENTION TO MOVE TO STRIKE PORTIONS OF THE DECLARATIONS OF FERNANDO ACEBEDO, DENNIS TUSSEY AND RUSSELL NG Assigned to the Honorable: Judge Susan Illston

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JOINT STIPULATION TO ENLARGE TIME Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and Rule 6-2 of the Local Rules for the United States District Court for the Northern District of California, the parties, by and through their undersigned counsel, hereby stipulate and agree that the time within which defendants Paul Financial LLC, Luminent Mortgage Trust 2006-2, and HSBC Bank USA, National Association may respond to plaintiff s Objections to and Notices of Intention to Move to Strike Portions of the Declarations of Fernando Acebedo, Dennis Tussey and Russell Ng is hereby enlarged up through and including May 1, 2009. In support thereof, the parties state as follows: 1. On April 10, 2009, plaintiff filed his Memorandum of Points and

Authorities in Opposition to Defendants Joint Motion for Summary Judgment. 2. In connection with this Memorandum, plaintiff also filed Objections to

and Notice of Intention to Move to Strike Portions of the Declaration of Fernando Acebedo, Objections to and Notice of Intention to Move to Strike Portions of the Declaration of Dennis Tussey, and Objections to and Notice of Intention to Move to Strike Portions of the Declaration of Russell Ng. On each of these Objections (collectively, the Objections ), plaintiff indicated a hearing date of May 15, 2009, the same date of the hearing on defendants Joint Motion for Summary Judgment. 3. To the extent that these Objections are deemed motions under the Federal

Rules of Civil Procedure and the Local Rules, responses would be due on April 24, 2009, twenty-one (21) days before the hearing date. However, Reply Briefs to Plaintiff s Memorandum of Points and Authorities in Opposition to Defendants Joint Motion for Summary Judgment are due on May 1, 2009.

JOINT STIPULATION TO ENLARGE TIME FOR DEFENDANTS TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF S OBJECTIONS TO, AND NOTICES OF INTENTION TO MOVE TO STRIKE PORTIONS OF THE DECLARATION OF FERNANDO ACEBEDO, DENNIS TUSSEY AND RUSSELL NG

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4.

To consolidate the filings in this matter, the parties agree and stipulate

that the defendants shall have up to and including May 1, 2009 to file responses to the Objections. 5. This stipulated enlargement of time will not alter the date of any event or

any deadline already fixed by Court order. Further, the parties anticipate that the Objections will be heard, if at all, at the hearing on May 15, 2009. SO STIPULATED: Dated: April 22, 2009 By: /s/ _Irene C. Freidel_________________ Irene C. Freidel (pro hac vice) [e-mail] Phoebe S. Winder (pro hac vice) [e-mail] David D. Christensen (pro hac vice) [e-mail] K&L GATES LLP State Street Financial Center One Lincoln Street Boston, Massachusetts 02111 Telephone: [phone] Facsimile: [phone] Matthew G. Ball (SBN NO. 208881) [e-mail] K&L GATES LLP 55 Second Street, Suite 1700 San Francisco, California 94105-3493 Telephone: ( 4 1 5 ) 8 8 2 - 8 2 0 0 Facsimile: [phone] Attorneys for Defendant HSBC National Association and Luminent Mortgage Trust 2006-2

JOINT STIPULATION TO ENLARGE TIME FOR DEFENDANTS TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF S OBJECTIONS TO, AND NOTICES OF INTENTION TO MOVE TO STRIKE PORTIONS OF THE DECLARATION OF FERNANDO ACEBEDO, DENNIS TUSSEY AND RUSSELL NG

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Dated: April 22, 2009

By: /s/ _Lee A. Weiss_________________ Lee A. Weiss (admitted pro hac vice) [e-mail] Rebecca Tingey (admitted pro hac vice) [e-mail] BROWNE WOODS GEORGE LLP 49 West 37th Street, 15th Floor New York, New York 10018 Phone: [phone] Fax: [phone] David M. Arbogast (SBN 167571) [e-mail] Jeffrey K. Berns, Esq. (SBN 131351) [e-mail] ARBOGAST & BERNS LLP 19510 Ventura Boulevard, Suite 200 Tarzana, California 91356 Phone: [phone] Fax: [phone] Attorneys for Plaintiff Gregory Jordan

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Dated: April 22, 2009

By: /s/ _John P. Christian_________________ John P. Christian, Esq. Tobin & Tobin 500 Sansome Street, 8th Floor San Francisco, CA 94111 415-433-1400 415-772-9615 (direct dial) 415-433-3883 (fax) www.tobinlaw.com (website [e-mail] (e-mail) Attorney for Paul Financial LLC S DISTRICT TE C TA
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JOINT STIPULATION TO ENLARGE TIME FOR DEFENDANTS TO ANSWER, MOVE, OR OTHERWISE RESPOND TO PLAINTIFF S OBJECTIONS TO, AND NOTICES OF INTENTION TO MOVE TO STRIKE PORTIONS OF THE DECLARATION OF FERNANDO ACEBEDO, DENNIS TUSSEY AND RUSSELL NG

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