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

Filing 39

STIPULATION WITH PROPOSED ORDER STIPULATION TO CONSOLIDATE HEARINGS ON DEFENDANTS' MOTION TO DISMISS AND PLAINTIFFS' MOTION FOR PRELIMINARY INJUNCTION AND FOR RELATED RELIEF filed by City of Richmond, California, Mortgage Resolution Partners LLC. (Attachments: # 1 Proposed Order)(Kronland, Scott) (Filed on 8/26/2013)

1 STEPHEN P. BERZON (SBN 46540)
SCOTT A. KRONLAND (SBN 171693)
2 JONATHAN WEISSGLASS (SBN 185008)
ERIC P. BROWN (SBN 284245)
3 Altshuler Berzon LLP
4 177 Post Street, Suite 300
San Francisco, CA 94108
5 Tel: [phone]
Fax: [phone]
6 E-mail: [e-mail]
[e-mail]
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[e-mail]
[e-mail]
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9 Attorneys for Defendants City of Richmond and
Mortgage Resolution Partners LLC
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BRUCE REED GOODMILLER (SBN 121491)
WILLIAM A. FALIK (SBN 53499)
11
City Attorney
100 Tunnel Rd
CARLOS A. PRIVAT (SBN 197534)
Berkeley, CA 94705
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Assistant City Attorney
Tel: [phone]
Fax: [phone]
13 CITY OF RICHMOND
450 Civic Center Plaza
E-mail: [e-mail]
14 Richmond, CA 94804
Telephone: [phone]
Attorney for Defendant
15
Facsimile: [phone]
Mortgage Resolution Partners LLC
E-mail: [e-mail]
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[e-mail]
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Attorneys for Defendant City of Richmond
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

22 WELLS FARGO BANK, NATIONAL
ASSOCIATION, as Trustee, et al.,
23
Plaintiffs,

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25

v.

26 CITY OF RICHMOND, CALIFORNIA, a
27 municipality, and MORTGAGE
RESOLUTION PARTNERS LLC,
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Defendants.

Case No. CV-13-3663-CRB
STIPULATION TO CONSOLIDATE
HEARINGS ON DEFENDANTS’ MOTION
TO DISMISS AND PLAINTIFFS’
MOTION FOR PRELIMINARY
INJUNCTION AND FOR RELATED
RELIEF

Honorable Charles R. Breyer

Stipulation to Consolidate Hearings, Case No. CV-13-3663-CRB

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WHEREAS, Plaintiffs have moved for a preliminary injunction;

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WHEREAS, Defendants filed an opposition to the preliminary injunction motion on

3 August 22, 2013;
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WHEREAS, Defendants filed a 7-page motion to dismiss this action for lack of subject

5 matter jurisdiction on August 23, 2013;
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WHEREAS, the contentions in Defendants’ motion to dismiss are also set forth as part of

7 their opposition to the preliminary injunction motion;
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WHEREAS, the parties agree that it makes sense for the Court to consider the motion to

9 dismiss contemporaneously with the motion for preliminary injunction;
10

WHEREAS, the preliminary injunction hearing is set for September 13, 2013, and the

11 motion to dismiss hearing is set for October 11, 2013;
12

WHEREAS, the parties have previously agreed that the hearing date on the preliminary

13 injunction can be moved to September 9, 10, 11, or 12, 2013, to accommodate the vacation
14 schedule of Defendants’ lead counsel (Doc. 25);
15

IT IS HEREBY STIPULATED by all parties as follows:

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1.

Plaintiffs will file their opposition to the motion to dismiss by August 30, 2013;

17

2.

Defendants will file any reply on the motion to dismiss by September 4, 2013; and

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3.

The hearing on the preliminary injunction and the motion to dismiss can be moved to

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September 9, 10, 11, or 12, 2013.

20 Dated: August 23, 2013

ALTSHULER BERZON LLP

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

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ATTORNEYS FOR DEFENDANTS
CITY OF RICHMOND, CALIFORNIA
MORTGAGE RESOLUTION PARTNERS LLC

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Stipulation to Consolidate Hearings, Case No. CV-13-3663-CRB

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

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I attest that concurrence in the filing of this document has been obtained from Rocky C.

10 Tsai, whose conformed signature is set forth above.
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/s/ Scott A. Kronland
____________________________________
Scott A. Kronland

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Stipulation to Consolidate Hearings, Case No. CV-13-3663-CRB