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

Filing 74

STIPULATION AND ORDER re 73 STIPULATION WITH PROPOSED ORDER Discovery Dates filed by Chris Romo. Discovery due by 2/26/2017. Signed by Judge Edward M. Chen on 1/10/17. (bpfS, COURT STAFF) (Filed on 1/10/2017)

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NELSON W. GOODELL, ESQ., SBN 264734
The Goodell Law Firm
5 Third Street, Suite 1100
San Francisco, CA 94103
Tel. No. [phone]
Fax No. [phone]
Email: [e-mail]

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Attorney for Plaintiffs
CHRIS ROMO AND DULIA ROMO

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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CHRIS ROMO AND MARIA DULIA

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

ROMO,

STIPULATION AND [PROPOSED]
ORDER RE: DISCOVERY

Plaintiffs,

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v.

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WELLS FARGO BANK, N.A. WELLS
FARGO HOME MORTGAGE and Does 1
through 20, inclusive,

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Defendants.

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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:

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WHEREAS, the Plaintiffs served Defendants with discovery requests on November 18,
2016;

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WHEREAS, Defendants served Plaintiffs with discovery requests on December 21, 2016;

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WHEREAS, Defendants have yet to respond to Plaintiffs’ discovery requests;

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WHEREAS, discovery cut-off is set for January 26, 2017, expert reports are due by

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January 26, 2017, rebuttal reports are due by February 16, 2017, and expert discovery cut-off is

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set for March 9, 2017.

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WHEREAS, Defendants have indicated they wish to depose Plaintiffs but no date has
been set yet.
NOW IT IS HEREBY STIPULATED AND AGREED by and between Defendants and
Plaintiffs, through their undersigned counsel of record that:

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Fact Discovery cut-off will now be February 26, 2017.

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2.

Initial Expert Reports will now be due on February 26, 2017.

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3.

Rebuttal Reports will now be due on March 16, 2017.

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4.

Expert Discovery cut-off will now be April 9, 2017.

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IT IS SO STIPULATED.

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Dated: January 4, 2017

__/s/ Nelson Goodell___________
NELSON W. GOODELL,
Attorney for Plaintiff, CHRIS ROMO
and MARIA DULIA ROMO

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Approved as to form and content:

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Dated: January 4, 2017

__/s/ Videll Lee Heard_________
VIDDELL LEE HEARD,
Attorney for Wells Fargo

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CERTIFICATION

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Pursuant to Civil Local Rule 5-1(i)(3), I attest that I have obtained concurrence from

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Defendant’s counsel for the filing of this document.

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Dated: January 4, 2017

__/s/ Nelson W. Goodell_____
NELSON W. GOODELL,
Attorney for Plaintiffs

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ORDER

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Fact Discovery and initial Expert Reports will now be due on February 26, 2017. Rebuttal
Reports will be due March 16, 2017, and Expert Discovery cut-off will be moved to April 9,

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S

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NO

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______________________________
DERED
SO OR ED
United States District Judge Edward
IT IS
DIFI
M. Chen
AS MO

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dward
Judge E

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R NIA

1/10/2017

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M. Che

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Dated:

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IT IS SO ORDERED.

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All other dates remain the same.

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2017.

UNIT
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