Omega et al v. Wells Fargo & Co.,

Filing 8

STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO INITIAL COMPLAINT BY NOT MORE THAN 30 DAYS. Signed by Judge Joseph C. Spero on 06/09/11. (klhS, COURT STAFF) (Filed on 6/9/2011)

Case3:11-cv-02621-JCS Document7
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Filed06/08/11 Page1 of 4

Lynette Gridiron Winston (#151003)
[e-mail]
Melissa M. Coyle (#232775)
[e-mail]
Anglin, Flewelling, Rasmussen,
Campbell & Trytten LLP
199 S. Los Robles Avenue, Suite 600
Pasadena, California 91101-2459
Tel: [phone]
Fax: [phone]

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Attorneys for Defendant
Wachovia Mortgage, a division of Wells Fargo
Bank, N.A., fraudulently joined and sued as
“Wells Fargo & Co.” (“Wells Fargo”)

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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FLORENCIO L. OMEGA and JUANITA T.
OMEGA,
Plaintiffs,
vs.

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WELLS FARGO & CO.; and DOES 1-250,
inclusive,
Defendants.

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Case No.: 3:11-CV-02621-JCS
[Assigned to the Honorable Joseph C. Spero,
Courtroom ]
STIPULATION TO EXTEND TIME TO
RESPOND TO INITIAL COMPLAINT BY
NOT MORE THAN 30 DAYS (L.R. 6-1(A))
Complaint Served:
Date Removed:
Current Response Date:
New Response Date:

May 16, 2011
June 1, 2011
June 8, 2011
June 22, 2011

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TO THE CLERK AND THE HONORABLE JOSEPH C. SPERO, DISTRICT COURT

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MAGISTRATE:

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Plaintiffs Florencio L. Omega and Juanita T. Omega (“Plaintiffs”) and defendant Wells

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Fargo Bank, N.A. successor by merger with Wells Fargo Bank Southwest, N.A., formerly

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known as Wachovia Mortgage, FSB, formerly known as World Savings Bank, FSB and

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fraudulently joined and sued as “Wells Fargo & Co.” (“Wells Fargo”) present the following

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stipulation extending the time for Wells Fargo to respond to plaintiffs’ Complaint.
*95451/000889/00170109-1

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CASE NO.: C11-02621-JCS
STIPULATION TO EXTEND TIME TO
RESPOND TO INITIAL COMPLAINT

Case3:11-cv-02621-JCS Document7
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Filed06/08/11 Page2 of 4

STIPULATION
1.

On or about May 13, 2011, plaintiffs filed their Complaint against Wells Fargo.

Plaintiffs personally served Wells Fargo on May 16, 2011.
2.

On or about June 1, 2011, Wells Fargo removed the case to the United States

District Court, Northern District of California.

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3.

Wells Fargo’s response to the Complaint is due on June 8, 2011.

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4.

The parties have agreed to an extension of two weeks, until June 22, 2011, for

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Wells Fargo to respond to the Complaint.
5.

This is the parties’ first request for an extension for Wells Fargo to respond to the

Complaint.
IT IS SO STIPULATED.

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Respectfully submitted,

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Dated: June 8, 2011

ANGLIN, FLEWELLING, RASMUSSEN,
CAMPBELL & TRYTTEN LLP

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By:

/s/ Melissa M. Coyle
Melissa M. Coyle
[e-mail]
Attorneys for Defendant
Wachovia Mortgage, a division of Wells Fargo
Bank, N.A., fraudulently joined and sued as
“Wells Fargo & Co.”

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Dated: June 8, 2011

HOLLAND LAW FIRM

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C. Spero

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*95451/000889/00170109-1

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ORDERED

Judge Joseph

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. Spero

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Judge Jo

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DERED

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Dated: June 9, 2011

Juanita T. Omega

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UNIT
ED

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RT
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By:
/s/
S DISTRICT Cometria Cooper
TE
Cometria Cooper
C
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Attorneys for Plaintiffs Florencio L. Omega and

A

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N

D I S T I2 T
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OF

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CASE NO.: C11-02621-JCS
STIPULATION TO EXTEND TIME TO
RESPOND TO INITIAL COMPLAINT

Case3:11-cv-02621-JCS Document7

Filed06/08/11 Page3 of 4

ATTESTATION PURSUANT TO GENERAL ORDER 45

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I, Melissa M. Coyle, attest that concurrence in the filing of this document has been
obtained from each of the signatories. I declare under penalty of perjury under the laws of the
United States of America that the foregoing is true and correct. Executed this 8th day of June,
2011.

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/s/ Melissa M. Coyle
[e-mail]

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*95451/000889/00170109-1

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CASE NO.: C11-02621-JCS
STIPULATION TO EXTEND TIME TO
RESPOND TO INITIAL COMPLAINT

Case3:11-cv-02621-JCS Document7

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Filed06/08/11 Page4 of 4

CERTIFICATE OF SERVICE

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I, the undersigned, declare that I am over the age of 18 and am not a party to this
action. I am employed in the City of Pasadena, California; my business address is Anglin,
Flewelling, Rasmussen, Campbell & Trytten LLP, 199 S. Los Robles Avenue, Suite 600,
Pasadena, California 91101-2459.
On the date below, I served a copy of the following document(s):

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STIPULATION TO EXTEND TIME TO RESPOND TO INITIAL COMPLAINT BY NOT
MORE THAN 30 DAYS (L.R. 6-1(A))

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on all interested parties in said case addressed as follows:

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Served Electronically via Court’s CM/ECF System:

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Attorneys for Plaintiff

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George Holland, Jr., Esq.
Holland Law Firm
1970 Broadway
Suite 1030
Oakland, CA 94612
Tel: [phone]

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FEDERAL: I declare under penalty of perjury under the laws of the United States of
America that the foregoing is true and correct. I declare that I am employed in the office of a
member of the Bar of this Court at whose direction the service was made. This declaration is
executed in Pasadena, California, on June 8, 2011.

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Teresa L. Zunino
(Print name)

/s/ Teresa L. Zunino
(Signature)

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*95451/000889/00170109-1

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CASE NO. C11-02621-JCS
CERTIFICATE OF SERVICE