Wilson v. JPMorgan Chase Bank, National Association

Filing 13

ORDER GRANTING 11 Stipulation To Extend Responsive Pleading Deadline filed by JPMorgan Chase Bank, National Association. Signed by Chief Magistrate Judge Joseph C. Spero on 4/1/16. (klhS, COURT STAFF) (Filed on 4/1/2016)

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SEYFARTH SHAW LLP
Kathryn C. Palamountain (Cal. Bar No. 183246)
[e-mail]
700 Milam Street, Suite 1400
Houston, Texas 77002-2812
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
JPMORGAN CHASE BANK, N.A.

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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RONNIE-MARIE WILSON,

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Plaintiff

CASE NO.: 3:16-cv-00577-JCS
JOINT STIPULATION TO EXTEND
RESPONSIVE PLEADING DEADLINE

v.
JPMORGAN CHASE BANK,
NATIONAL ASSOCIATION,
Defendant.

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This Stipulation is made by and between Plaintiff RONNIE-MARIE WILSON

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(“Plaintiff”),

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ASSOCIATION (“JPMorgan”) (collectively, “the Parties”), by and through their

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respective counsel of record, with reference to the following facts:

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and

Defendant

JPMORGAN

CHASE

BANK,

NATIONAL

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Plaintiff filed his Complaint against Defendant on February 3, 2016.

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Defendant waived service on February 12, 2016.

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The responsive pleading is currently due April 12, 2016.

4.

The allegations of the Complaint involve conditions at a JPMorgan branch.

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JOINT STIPULATION TO EXTEND RESPONSIVE PLEADING DEADLINE
25861187v.1

5.

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Parties are exploring the possibility of an early resolution of this

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matter and believe that settlement may be possible without the need for Defendant to file

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a responsive pleading.
6.

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The parties have stipulated to a three-week extension of the

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responsive deadline, making the proposed deadline for JPMorgan to file a responsive

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pleading May 3, 2016.
7.

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The Parties have not previously requested a time extension in this case

for any reason, and the stipulated extension will not interfere with other deadlines.
NOW THEREFORE, the Parties stipulate and jointly request that the Court extend
the responsive pleading deadline from April 12, 2016 to May 3, 2016.
SO STIPULATED.

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DATED: April 1, 2016

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Respectfully submitted,

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Respectfully submitted,

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MOORE LAW FIRM, P.C.

SEYFARTH SHAW LLP

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UNIT
ED

S

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ISTRIC
ES D
TC
AT
T

NO

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Dated: 4/1/16

RT
U
O

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ERED

O ORD

IT IS S

seph C.

Judge Jo

Spero

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H

ER

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R NIA

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Attorneys for Plaintiff
RONNIE-MARIE WILSON

FO

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Attorneys for Defendant
JPMORGAN CHASE BANK,
NATIONAL ASSOCIATION

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By: /s/ Tanya E. Moore (by permission)
Tanya E. Moore

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By: /s/ Kathryn C. Palamountain
Kathryn C. Palamountain

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F
D IS T IC T O
R

C

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JOINT STIPULATION TO EXTEND RESPONSIVE PLEADING DEADLINE
25861187v.1

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SIGNATURE ATTESTATION

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I hereby attest that all signatories listed above, on whose behalf this stipulation is
submitted, concur in the filing’s content and have authorized the filing.

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Dated: April 1, 2016

By:/s/ Kathryn C. Palamountain
Kathryn C. Palamountain

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Attorneys for Defendant
JPMORGAN CHASE BANK

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CERTIFICATE OF SERVICE

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I, do hereby certify that I have caused a true and correct copy of the foregoing

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document to be served upon the following by filing the same with the Court’s CM/ECF

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electronic filing system on this 1st day of April 2016:

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Tanya E. Moore
Moore Law Firm, P.C.
332 North Second Street
San Jose, California 95112
[e-mail]

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Attorneys for Plaintiff

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/s/ Kathryn C. Palamountain
Kathryn C. Palamountain

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JOINT STIPULATION TO EXTEND RESPONSIVE PLEADING DEADLINE
25861187v.1