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

Filing 43

STIPULATION AND ORDER. Case Management Statement due by 6/23/2016. Further Case Management Conference set for 6/30/2016 10:30 AM in Courtroom 5, 17th Floor, San Francisco. Signed by Judge Edward M. Chen on 6/6/16. (bpfS, COURT STAFF) (Filed on 6/6/2016)

A NGLIN F LEWELLING R ASMUSSEN C AMPBELL & T RYTTEN LLP

1 Viddell Lee Heard (# 175049)
[e-mail]
2 ANGLIN, FLEWELLING, RASMUSSEN,
CAMPBELL & TRYTTEN LLP
3 199 South Los Robles Avenue, Suite 600
Pasadena, California 91101-2459
4 Telephone: [phone] | Facsimile: [phone]
5 Attorneys for Defendant
WELLS FARGO BANK, N.A., successor by
6 merger with Wells Fargo Bank Southwest, N.A.,
f/k/a Wachovia Mortgage, FSB, f/k/a WORLD
7 SAVINGS BANK, FSB (erroneously sued as
“Wells Fargo Home Mortgage, Inc.”)
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Nelson W. Goodell, Esq.
9 [e-mail]
THE GOODELL LAW FIRM
10 5 Third St., Suite 1100
San Francisco, California, 94103
11 Telephone: [phone] | Facsimile: [phone]
12 Attorneys for Plaintiffs
CHRIS ROMO and MARIA DULIA ROMO
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA – SAN FRANCISCO DIVISION

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CHRIS ROMO and MARIA DULIA ROMO

CASE NO. 3:15-cv-03708-EMC

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Plaintiffs,

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[The Honorable Edward M. Chen]

v.

JOINT STIPULATION AND
[PROPOSED] ORDER TO CONTINUE
CASE MANAGEMENT CONFERENCE

20 WELLS FARGO BANK, N.A. WELLS
FARGO HOME MORTGAGE; and Does 1-20;
21 inclusive,
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Current Date:

Defendants.

June 10, 2016

Proposed Date: June 23, 2016
Time:
9:30 a.m.
Ctrm:
5 – 17th Floor

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25 TO THE CLERK OF THE COURT AND THE HONORABLE DISTRICT JUDGE:
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Plaintiffs Chris Romo and Maria Dulia Romo and defendants WELLS FARGO BANK,

27 N.A., successor by merger with Wells Fargo Bank Southwest, N.A., f/k/a Wachovia Mortgage,
28 FSB, f/k/a WORLD SAVINGS BANK, FSB (erroneously sued as Wells Fargo Home Mortgage)
93000/BR1696/01434717-1

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CASE NO.: 3:16-CV-03708-EMC
JOINT STIPULATION

1 (“Wells Fargo”) enter into the below stipulation and hereby request that the Court enter the
2 accompanying proposed order. Plaintiffs and Wells Fargo jointly stipulate as follows:
WHEREAS, the Court originally scheduled a Case Management Conference for June 2,

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4 2016 (Doc. # 31). The parties filed their Joint Case Management Statement on May 26, 2016
5 (Doc. # 39).
WHEREAS, On May 31, 2016, the Court continued the hearing to June 10, 2016 (Doc. #

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A NGLIN F LEWELLING R ASMUSSEN C AMPBELL & T RYTTEN LLP

7 40).
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WHEREAS, counsel for Plaintiff and counsel for Wells Fargo are each unavailable on

9 June 10. Counsel for Wells Fargo has a court-ordered mediation on June 10 at 12:00 in
10 Monterey, a mediation that he must attend in person. Counsel for Plaintiff has a proposed
11 Statement of Decision and post-trial brief due on this day, which will require his attention for the
12 vast majority of this day.
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WHEREAS, both counsel for Plaintiff and counsel for Wells Fargo are available on June

14 23, 2016.
STIPULATION

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16 NOW THEREFORE,
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IT IS HEREBY STIPULATED that the Case Management Conference be continued

18 from June 2, 2016 to June 23, 2016.
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Respectfully submitted,
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Dated: June 2, 2016

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ANGLIN, FLEWELLING, RASMUSSEN,
CAMPBELL & TRYTTEN LLP
/s/ Viddell Lee Heard
Viddell Lee Heard
[e-mail]
Attorneys for Defendant
WELLS FARGO BANK, N.A., successor by
merger with Wells Fargo Bank Southwest, N.A.,
f/k/a Wachovia Mortgage, FSB, f/k/a WORLD
SAVINGS BANK, FSB (“Wells Fargo”)

By:

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93000/BR1696/01434717-1

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CASE NO.: 3:16-CV-03708-EMC
JOINT STIPULATION

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Respectfully submitted,

2 Dated: June 2, 2016

THE GOODELL LAW FIRM

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/s/ Nelson W. Goodell
Nelson W. Goodell
Attorneys for Plaintiffs
CHRIS ROMO and MARIA DULIA ROMO
By:

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A NGLIN F LEWELLING R ASMUSSEN C AMPBELL & T RYTTEN LLP

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93000/BR1696/01434717-1

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CASE NO.: 3:16-CV-03708-EMC
JOINT STIPULATION

CERTIFICATION

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Pursuant to Civil Local Rule 5-1(i)(3), I attest that I have obtained concurrence from
Plaintiffs’ counsel for the filing of this document.

__/s/ Viddell Lee Heard___
VIDDELL LEE HEARD
Attorney for Defendants

Dated: June 2, 2016

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A NGLIN F LEWELLING R ASMUSSEN C AMPBELL & T RYTTEN LLP

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93000/BR1696/01434717-1
{93000/BR1696/01434717-1 }

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CASE NO.: 3:16-CV-03708-EMC
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ORDER

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The Case Management Conference currently scheduled for June 10, 2016 is hereby
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10:30

continued to June 23, 2016 at 9:30 a.m.

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RT

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dward
Judge E

ER

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M. Che

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DERED
SO OR ED
IT IS District IFI
United StatesS MODJudge Edward M. Chen
A

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6/6/2016

UNIT
ED

Dated:

NO

A NGLIN F LEWELLING R ASMUSSEN C AMPBELL & T RYTTEN LLP

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S DISTRICT
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6 IT IS SO ORDERED.

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93000/BR1696/01434717-1
{93000/BR1696/01434717-1 }

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CASE NO.: 3:16-CV-03708-EMC
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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 199 S. Los Robles
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Avenue, Suite 600, Pasadena, California 91101-2459.
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On June 2, 2016, I served the foregoing document entitled:
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JOINT STIPULATION AND [PROPOSED] ORDER
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TO CONTINUE CASE MANAGEMENT CONFERENCE

A NGLIN F LEWELLING R ASMUSSEN C AMPBELL & T RYTTEN LLP

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on the interested parties in said case as follows:

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Served Via The Court’s CM/ECF System:
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Attorneys for Plaintiffs:

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Nelson W. Goodell, Esq.
THE GOODELL LAW FIRM
5 Third Street, Suite 1100
San Francisco, CA 94103

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Tel: [phone]

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Fax: [phone]

[e-mail]

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I declare under penalty of perjury under the laws of the United States of America that
17 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
18 Pasadena, California, on June 2, 2016.
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/s/ Marianne Mantoen
(Signature of Declarant)

Marianne Mantoen
(Type or Print Name)

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93000/BR1696/01434717-1
{93000/BR1696/01434717-1 }

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CASE NO.: 3:16-CV-03708-EMC
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