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

Filing 33

STIPULATION AND ORDER re 32 STIPULATION WITH PROPOSED ORDER re: Revision of Briefing Schedule filed by Chris Romo. Signed by Judge Edward M. Chen on 3/29/16. (bpf, COURT STAFF) (Filed on 3/29/2016)

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1 2 3 4 NELSON W. GOODELL, ESQ., SBN 264734 The Goodell Law Firm 5 Third Street, Suite 1100 San Francisco, CA 94103 Tel. No. (415) 495-3950 Fax No. (415) 495-6900 Email: nelson@goodelllawsf.com 5 6 7 Attorney for Plaintiffs CHRIS ROMO AND DULIA ROMO 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 11 12 13 CHRIS ROMO AND MARIA DULIA CASE NO.: 3:15-cv-03708-EMC ROMO, STIPULATION AND [PROPOSED] ORDER RE: REVISION OF BRIEFING SCHEDULE Plaintiffs, 14 v. 15 17 WELLS FARGO BANK, N.A. WELLS FARGO HOME MORTGAGE and Does 1 through 20, inclusive, 18 Defendants. 16 19 20 21 22 23 24 25 26 TO THE CLERK OF THE COURT AND THE HONORABLE JUDGE EDWARD M. CHEN: Having met and conferred, Plaintiffs Chris Romo and Dulia Romo (the “plaintiffs”) and Defendant Wells Fargo Bank, N.A. (“Wells Fargo”) enter into the below stipulation and hereby request that the Court enter the accompanying proposed order. Plaintiffs and Wells Fargo, by and through their respective counsel, jointly stipulate as follows: 27 28 1 1 2 WHEREAS, the Defendants filed a Motion to Dismiss Plaintiffs’ Second Amended Complaint on March 14, 2016; 3 WHEREAS the Plaintiffs intend to file an Opposition to Defendants’ Motion, but 4 Plaintiffs’ counsel has been involved in extensive pre-trial preparation in a matter pending in the 5 San Francisco Superior Court that is scheduled to begin trial on April 11, 2016, and is flying to 6 Washington, D.C. on Friday, April 1, 2016, to be sworn in as a member of the Bar for the 7 Supreme Court of the United States, and as a result, has not had sufficient time to prepare this 8 Opposition; 9 10 WHEREAS, Plaintiffs’ counsel requests an additional three days to file his opposition, and intends to file it on March 31, 2016; 11 WHEREAS, Defendants’ counsel consents to Plaintiffs’ request. 12 Pursuant to Civil Local Rule 6-2, this is the third request in this case to modify time 13 deadlines in this case. The parties do not think that this modification would have any meaningful 14 impact on the schedule for this case. 15 16 17 NOW IT IS HEREBY STIPULATED AND AGREED by and between Defendants and Plaintiffs, through their undersigned counsel of record that: 1. 18 Plaintiffs’ Opposition to Defendants’ Motion to Dismiss shall be filed on March 31, 2016. 19 2. Defendants’ Reply to Plaintiffs’ Opposition shall be filed on April 7, 2016. 20 3. The hearing date on Defendants’ Motion to Dismiss – April 21, 2016 – will 21 remain the same. 22 23 IT IS SO STIPULATED. 24 25 Dated: March 28, 2016 ___/s/ Nelson W. Goodell__ NELSON W. GOODELL, Attorney for Plaintiff, CHRIS ROMO and MARIA DULIA ROMO 26 27 28 2 1 Approved as to form and content: 2 3 Dated: March 28, 2016 __/s/ Viddell Lee Heard____ VIDDELL LEE HEARD, Attorney for Wells Fargo 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 3 1 CERTIFICATION 2 3 4 Pursuant to Civil Local Rule 5-1(i)(3), I attest that I have obtained concurrence from Defendant’s counsel for the filing of this document. 5 6 Dated: March 28, 2016 __/s/ Nelson W. Goodell___ NELSON W. GOODELL, Attorney for Plaintiff 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 4 1 ORDER 2 3 Plaintiffs’ counsel shall have until March 31, 2016, to file his Opposition to Defendants’ 4 Motion to Dismiss Plaintiffs’ Second Amended Complaint, and Defendants’ Reply to Plaintiffs’ 5 Opposition shall be filed on April 7, 2016. The hearing date will remain on April 21, 2016. S March 29, 2016 NO United States District Judge Edward M. Chen n M. Che Edward Judge 11 RT ER H 12 FO 10 R NIA Dated: D RDERE S SO O ______________________________ IT I LI IT IS SO ORDERED. 9 UNIT ED 8 RT U O 7 S DISTRICT TE C TA 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 5 A 6 N F D IS T IC T O R C

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