Choudhuri v. Wells Fargo Bank, N.A. et al

Filing 66

STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO MOTION FOR PRELIMINARY INJUNCTION. Responses due by 10/6/2016. Reply deadline 10/13/2016. Signed by Judge Vince Chhabria on 9/13/16. (cl, COURT STAFF) (Filed on 9/13/2016)

1 MARK D. LONERGAN (State Bar No. 143622)
THOMAS N. ABBOTT (State Bar No. 245568)
2 KIMBERLY A. PAESE (State Bar No. 258594)
[e-mail]
3 SEVERSON & WERSON
A Professional Corporation
4 One Embarcadero Center, Suite 2600
San Francisco, California 94111
5 Telephone: [phone]
Facsimile: [phone]
6
Attorneys for Defendants
7 WELLS FARGO BANK, N.A.; and
TREENA BERLINKSY
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UNITED STATES DISTRICT COURT
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NORTHERN DISTRICT OF CALIFORNIA — SAN FRANCISCO DIVISION
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11 KABITA CHOUDHURI,

Case No. 3:15-cv-03608-VC

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STIPULATION AND PROPOSED ORDER
TO EXTEND TIME TO RESPOND TO
MOTION FOR PRELIMINARY
INJUNCTION

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Plaintiff,
vs.

14 WELLS FARGO BANK, N.A.; TREENA
BERLINSKY,
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Defendants.
16

The Hon. Vince Chhabria
Action Filed:
Trial Date:

August 6, 2015
None Set

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3:15-cv-03608-VC
STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO MOTION FOR PRELIMINARY
INJUNCTION

55000.1667/8513250.1

Pursuant to Local Rule 6-2, defendants Wells Fargo Bank, N.A. (“Wells Fargo”) and

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2 Treena Berlinsky (“Defendants”) and plaintiff Kabita Choudhuri (“Plaintiff”), hereby request the
3 Court extend the time for briefing on the motion for a preliminary injunction filed by Plaintiff, and
4 currently set for hearing on October 27, 2016 at 10:00 a.m., and hereby agree as follows:
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1.

Defendants’ response to Plaintiff’s motion for a preliminary injunction is currently

6 due September 23, 2016;
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2.

Under the current deadline, Defendants will not have sufficient time to prepare its

8 evidence in response to Plaintiff’s motion or a preliminary injunction;
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3.

The motion was filed on September 9, 2016 and the parties have made their request

10 to extend time prior to fourteen (14) days before the hearing;
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4.

Plaintiff previously filed a motion for preliminary injunction at the commencement

12 of this case in 2015, but the matter was taken off-calendar and never heard although the Court
13 ordered the temporary restraining order to remain in place until an eventual hearing;
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5.

This is the first request to extend time the parties have made pursuant to the motion

15 filed on September 9, 2016;
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6.

Upon information and belief, the parties do not believe this request for an extension

17 of time will prejudice any party or inconvenience the Court.
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Accordingly, subject to the approval of the Court, the parties stipulate as follows:

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1.

Defendants shall file and serve a response to Plaintiff’s motion for preliminary

20 injunction by October 6, 2016; and
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2.

Plaintiff may file a reply to Defendants’ response by October 13, 2016.

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3:15-cv-03608-VC
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STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO MOTION FOR PRELIMINARY
INJUNCTION

55000.1667/8513250.1

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IT IS SO STIPULATED.

2 DATED: September 12, 2016
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SEVERSON & WERSON
A Professional Corporation

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By:

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/s/ Kimberly A. Paese
Kimberly A. Paese

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Attorneys for Defendant WELLS FARGO BANK, N.A.

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8 DATED: September 12, 2016
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/s/ Kabita Choudhuri
Approved 9/12/16

By:

Kabita Choudhuri

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Plaintiff in Pro Se

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ECF ATTESTATION

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I hereby attest that I have on file all holographic signatures corresponding to any signatures
indicated by a conformed signature (/S/) within this e-filed document.

17 DATED: September 12, 2016
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SEVERSON & WERSON
A Professional Corporation

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By:

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/s/ Kimberly A. Paese
Kimberly A. Paese

Attorneys for Defendant WELLS FARGO BANK, N.A.

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PURSUANT TO STIPULATION, IT IS SO ORDERED:
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DATED: September ___, 2016

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HON
HON. VINCE CHHABRIA

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3:15-cv-03608-VC
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STIPULATION AND PROPOSED ORDER TO EXTEND TIME TO RESPOND TO MOTION FOR PRELIMINARY
INJUNCTION

55000.1667/8513250.1