Ragde et al., v. Wells Fargo & Company, et al.,

Filing 15

ORDER granting extending deadline for answer and continuing case management conference to 7/10/09. re 14 (ts, COURT STAFF) (Filed on 5/6/2009)

Case 3:09-cv-00226-SI

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JAMES R. MCGUIRE (CA SBN 189275) NATALIE NAUGLE (CA SBN 240999) MORRISON & FOERSTER LLP 425 Market Street San Francisco, California 94105-2482 Telephone: [phone] Facsimile: 415.268.7522 Attorneys for Defendants WELLS FARGO & COMPANY, WACHOVIA MORTGAGE CORPORATION, WACHOVIA BANK, N.A., WACHOVIA SECURITIES, LLC, WACHOVIA SECURITIES FINANCIAL NETWORK, LLC UNITED STATES DISTRICT COURT

9 NORTHERN DISTRICT OF CALIFORNIA 10 SAN FRANCISCO DIVISION 11 12 13 14 Plaintiff, 15 v. 16 17 18 19 20 21 22 23 24 25 26 27 28
STIP FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT AND CONTINUE INITIAL CMC Case No. C 09-0226 SI

JORGE V. RAGDE, JR. AND JENNIFER J. RAGDE, On Behalf of Themselves and All Others Similarly Situated,

Case No.

C 09-0226-SI

WELLS FARGO & COMPANY, WACHOVIA MORTGAGE CORPORATION, WACHOVIA BANK, N.A., WACHOVIA SECURITIES, LLC, WACHOVIA SECURITIES FINANCIAL NETWORK, LLC, WACHOVIA CORPORATION, and DOES 1-10 Inclusive, Defendants.

STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT AND CONTINUE INITIAL CASE MANAGEMENT CONFERENCE AND RELATED DEADLINES

WHEREAS, on February 18, 2009, the parties submitted an amended stipulation to extend the defendants' time to respond to plaintiffs' initial complaint to April 2, 2009; WHEREAS, on March 30, 2009, the parties submitted a second stipulation to extend the defendants' time to respond to plaintiffs' initial complaint to May 4, 2009; WHEREAS, the Initial Case Management Conference in this matter is currently scheduled for Friday, May 29, 2009 at 2:30 p.m.;

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WHEREAS, the Parties' Rule 26(f) Report and Joint Case Management Statement are currently due May 22, 2009, 7 days prior to the Initial Case Management Conference; WHEREAS, the Parties are currently required to file ADR Certifications and a Stipulation to ADR Process or Notice of Need for ADR Phone Conference by May 8, 2009, 21 days prior to the Initial Case Management Conference; WHEREAS, the Parties, through their counsel, have engaged in an informal exchange of information and continue to engage in productive settlement discussions in the hope of resolving the issues presented in Plaintiffs' complaint without further litigation; WHEREAS, the parties wish to continue that process without incurring unnecessary expense; IT IS HEREBY STIPULATED AND AGREED pursuant to Local Rule 6-1(a), and Federal Rule of Civil Procedure 12(a), by and between plaintiffs Jorge V. Ragde, Jr. and Jennifer J. Ragde and defendants Wells Fargo & Company, Wachovia Mortgage Corporation, Wachovia Bank, N.A., Wachovia Securities, LLC, Wachovia Securities Financial Network, LLC, Wachovia Corporation, through their respective attorneys, that the time by which defendants may plead or otherwise respond to the Complaint shall be extended to and include Monday, June 8, 2009. IT IS FURTHER STIPULATED AND AGREED pursuant to Northern District Local Rules 6-2(a), 7-12, and 16-2(e), that the Initial Case Management Conference currently scheduled for Friday, May 29, 2009, shall be continued to Friday, July 10, 2009 or any date thereafter at the Court's convenience. Additionally, in accordance with FRCP 26(f) and Local Rule 16-9(a), the Parties Rule 26(f) Report and Joint Case Management Conference Statement will be due seven (7) days prior to the rescheduled Initial Case Management Conference. The ADR Certifications and a Stipulation to ADR Process or Notice of Need for ADR Phone Conference will be due twenty-one (21) days prior to the rescheduled Initial Case Management Conference.

STIP FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT AND CONTINUE INITIAL CMC Case No. C 09-0226 SI

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1 Dated: April 30, 2009 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
STIP FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT AND CONTINUE INITIAL CMC Case No. C 09-0226 SI

JEFFREY F. KELLER DENISE L. DÍAZ KELLER GROVER LLP.

By

/s/ Denise L. Díaz Denise L. Díaz

Attorneys for Individual and Representative Plaintiff JORGE V. RAGDE, JR. and JENNIFER J. RAGDE Dated: April 30, 2009 JAMES R. McGUIRE NATALIE NAUGLE MORRISON & FOERSTER LLP

By

/s/ James R. McGuire James R. McGuire

Attorneys for Defendant WELLS FARGO & COMPANY, WACHOVIA MORTGAGE CORPORATION, WACHOVIA BANK, N.A., WACHOVIA SECURITIES, LLC, WACHOVIA SECURITIES FINANCIAL NETWORK, LLC, WACHOVIA CORPORATION PURSUANT TO STIPULATION, IT IS SO ORDERED.

Dated:

By: Judge Susan Illston

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GENERAL ORDER 45 ATTESTATION In accordance with General Order 45, concurrence in the filing of this document has been obtained from Denise L. Diaz and I shall maintain records to support this concurrence for subsequent production for the court if so ordered or for inspection upon request by a party. Date: April 30, 2009 By /s/ James R. McGuire James R. McGuire

Attorneys for Defendant WELLS FARGO & COMPANY, WACHOVIA MORTGAGE CORPORATION, WACHOVIA BANK, N.A., WACHOVIA SECURITIES, LLC, WACHOVIA SECURITIES FINANCIAL NETWORK, LLC, WACHOVIA CORPORATION

STIP FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT AND CONTINUE INITIAL CMC Case No. C 09-0226 SI

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