Wells Fargo Bank, National Association et al v. City of Richmond, California et al

Filing 26

Joint MOTION to Relate Case with Stipulation filed by Deutsche Bank National Trust Company, Deutsche Bank Trust Company Americas, Wells Fargo Bank, National Association. (Attachments: # 1 Stipulation, # 2 Proposed Order, # 3 Exhibit A, # 4 Exhibit B)(Tsai, Rocky) (Filed on 8/16/2013)

4

ROCKY C. TSAI (SBN 221452)
([e-mail])
ROPES & GRAY LLP
Three Embarcadero Center
San Francisco, CA 94111-4006
Telephone: [phone]
Facsimile: [phone]

5

Attorneys for Plaintiffs Wells Fargo Bank,
N.A., as Trustee, et al.

1
2
3

6
7

ADDITIONAL COUNSEL LISTED
ON SIGNATURE PAGE

8
UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA

10
11

WELLS FARGO BANK, NATIONAL
ASSOCIATION, as Trustee, et al.

12
Plaintiffs,
13
14
15
16

v.
CITY OF RICHMOND, CALIFORNIA, a
municipality; and MORTGAGE
RESOLUTION PARTNERS LLC, a Delaware
limited liability company,

17

Case No. 3:13-cv-03663-CRB
STIPULATION IN SUPPORT OF JOINT
ADMINISTRATIVE MOTION TO
CONSIDER WHETHER CASES
SHOULD BE RELATED
[Civil L.R. 3-12, 7-11 & 7-12]

Defendants.

18
19
20
21
22

THE BANK OF NEW YORK MELLON (f/k/a
The Bank of New York), as Trustee, on behalf
of the Trusts listed in Exhibit A, and U.S.
BANK NATIONAL ASSOCIATION, as
Trustee, on behalf of the Trusts listed in Exhibit
B,

23
Plaintiffs,

Case No. 3:13-cv-03664-JCS
STIPULATION IN SUPPORT OF JOINT
ADMINISTRATIVE MOTION TO
CONSIDER WHETHER CASES
SHOULD BE RELATED
[Civil L.R. 3-12, 7-11 & 7-12]

24
25
26
27
28

v.
CITY OF RICHMOND, CALIFORNIA, a
municipality; RICHMOND CITY COUNCIL;
MORTGAGE RESOLUTION PARTNERS
LLC, a Delaware limited liability company; and
GORDIAN SWORD LLC, a Delaware limited
STIPULATION REGARDING RELATED CASES;
CASE NO. 3:13-CV-03663-CRB

1
2

liability company;
Defendants.

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
STIPULATION REGARDING RELATED CASES;
CASE NO. 3:13-CV-03663-CRB

1

WHEREAS, the undersigned parties believe that the action The Bank of New York

2

Mellon, as Trustee, on behalf of the Trusts listed in Exhibit A, et al. v. City of Richmond et al.,

3

No. 3:13-CV-03664-JCS (the “BNYM Action”) involves substantially similar parties, property,

4

transactions, or events as Wells Fargo Bank, N.A., as Trustee, et al. v. City of Richmond et al.,

5

No. 3:13-CV-03663-CRB (the “Wells Fargo Action”), such that it appears likely that there will

6

be an unduly burdensome duplication of labor and expense or conflicting results if the cases are

7

conducted before different Judges;

8
9

WHEREAS, the parties believe the BNYM and Wells Fargo Actions are “related cases”
under Northern District of California Civil Local Rule 3-12(a); and

10

WHEREAS, the parties believe that treatment of the BNYM and Wells Fargo Actions as

11

related would serve the interests of judicial economy and avoid the potential for conflicting

12

rulings;

13

IT IS HEREBY STIPULATED AND AGREED by Plaintiffs and Defendants, through

14

their respective counsel of record, that The Bank of New York Mellon, as Trustee, on behalf of

15

the Trusts listed in Exhibit A, et al. v. City of Richmond et al., No. 3:13-CV-03664-JCS, should

16

be related to Wells Fargo Bank, N.A., as Trustee, et al. v. City of Richmond, No. 3:13-CV-03663-

17

CRB.

18

IT IS SO STIPULATED.

19
20

Dated: August 16, 2013

21

ROPES & GRAY LLP
By: /s/ Rocky C. Tsai
____________________________________
Rocky C. Tsai

22
23

ATTORNEYS FOR PLAINTIFFS WELLS
FARGO BANK, N.A., AS TRUSTEE;
DEUTSCHE BANK NATIONAL TRUST
COMPANY, AS TRUSTEE; AND DEUTSCHE
BANK TRUST COMPANY AMERICAS, AS
TRUSTEE
CASE NO. 3:13-CV-03663-CRB

24
25
26
27

MAYER BROWN LLP

28

3
STIPULATION REGARDING RELATED CASES;
CASE NO. 3:13-CV-03664-JCS
707245928.2

1

By: /s/ Bronwyn F. Pollock
_____________________________________
Donald M. Falk
Bronwyn F. Pollock

2
3

5

ATTORNEYS FOR PLAINTIFF THE BANK OF
NEW YORK MELLON, AS TRUSTEE (F/K/A
THE BANK OF NEW YORK)
CASE NO. 3:13-CV-03664-JCS

6

JONES DAY

7

By: /s/ Matthew A. Martel
____________________________
Matthew A. Martel

4

8
9

ATTORNEYS FOR PLAINTIFF U.S. BANK
NATIONAL ASSOCIATION, AS TRUSTEE
Case No. 3:13-CV-03664-JCS

10
11
12

ALTSHULER BERZON LLP

13

By: /s/ Scott A. Kronland
____________________________________
Scott A. Kronland

14
15

ATTORNEYS FOR DEFENDANTS
Case No. 3:13-CV-03663-CRB
Case No. 3:13-CV-03664-JCS

16
17
18

I attest that concurrence in the filing of this document has been obtained from Bronwyn
19
F. Pollock, Matthew A. Martel, and Scott A. Kronland, whose conformed signatures are set forth
20
above.
21
/s/ Rocky C. Tsai
_________________________
Rocky C. Tsai

22
23
24
25
26
27
28

4
STIPULATION REGARDING RELATED CASES;
CASE NO. 3:13-CV-03663-CRB
________