Ali Rankankan v. JPMorgan Chase Bank, N.A.

Filing 13

ORDER GRANTING re 5 Stipulation to Extend Date to File Responsive Pleading to Plaintiff's Complaint filed by JPMorgan Chase Bank, N.A. Signed by Chief Magistrate Judge Joseph C. Spero on 4/18/16. (klhS, COURT STAFF) (Filed on 4/18/2016)

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JOHN M. SORICH (CA Bar No. 125223)
[e-mail]
RAFAEL GARCIA-SALGADO (CA Bar No. 283230)
[e-mail]
PARKER IBRAHIM & BERG LLC
695 Town Center Drive, 16th Floor
Costa Mesa, California 92626
Tel: [phone]
Fax: [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 - OAKLAND

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ALI RANKANKAN,

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Plaintiff,

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CASE NO.: 4:16-cv-1694-JCS_________
JUDGE: Joseph C. Spero
JOINT STIPULATION TO EXTEND
DATE TO FILE RESPONSIVE
PLEADING TO PLAINTIFF’S
COMPLAINT

v.

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J.P.MORGAN CHASE BANK, N.A.,
successor in interest to WASHINGTON
MUTUAL BANK, F.A.; U.S. BANK,
N.A., successor in interest to
GREENPOINT MORTGAGE
FUNDING, INC.; MTC FINANCIAL
INC., a California Corporation doing
business as TRUSTEE CORPS; ALL
PERSONS UNKNOWN, CLAIMING
ANY LEGAL OR EQUITABLE RIGHT,
TITLE, ESTATE, LIEN, OR INTEREST
IN THE PROPERTY DESCRIBED IN
THE COMPLAINT ADVERSE TO
PLAINTIFF’S TITLE, OR ANY CLOUD
ON PLAINTIFF’S TITLE THERETO,
and DOES 1 through 20, inclusive,

ACTION FILED:
REMOVED:

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Defendants.
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{00590845.DOCX }

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March 4, 2016
April 4, 2016

TO THE CLERK OF THE ABOVE-ENTITLED COURT, AND TO ALL

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PARTIES AND THEIR ATTORNEYS OF RECORD:
This stipulation (“Stipulation”) is entered into by the undersigned counsel for

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defendant JPMorgan Chase Bank, N.A., (“Chase” or “Defendant”), and the

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undersigned counsel for plaintiff Ali Rankankan (“Plaintiff”) (together with

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Defendant, the “Parties”).

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RECITALS

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WHEREAS, on March 4, 2016, Plaintiff filed a Complaint in Contra Costa

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Superior Court in the case entitled Rankankan v JPMorgan Chase Bank, N.A., et al,
Case No. C16-00405.
WHEREAS, on April 4, 2016, Defendant filed a Notice of Removal with this

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Court.
WHEREAS, April 11, 2016 is currently Defendant’s last date to file a

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responsive pleading to Plaintiff’s Complaint.
WHEREAS Plaintiff has agreed to extend Defendant’s deadline for filing a

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responsive pleading.
AGREEMENT

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FOR ADEQUATE CONSIDERATION, THE SUFFICIENCY OF WHICH IS

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ACKNOWLEDGED, AND FOR GOOD CAUSE, THE PARTIES STIPULATE AS

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FOLLOWS:
[SIGNATURES ON FOLLOWING PAGE]

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///

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{00590845.DOCX }

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The Parties agree that Defendant’s deadline to file a responsive pleading

shall be extended through and including April 20, 2016.
IT IS SO STIPULATED.

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DATED: April 11, 2016

PARKER IBRAHIM & BERG LLC

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By:/s/Rafael R. Garcia-Salgado
JOHN SORICH
RAFAEL R. GARCIA-SALGADO
Attorneys for JPMorgan Bank, N.A.

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DATED: April 11 , 2016

LAW OFFICES OF THOMAS EASTRIDGE

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By:/s/Thomas Eastridge
THOMAS EASTRIDGE
Attorneys for Plaintiff
ALI RANKANKAN

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[E-Signature authorized on April 11, 2016]

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The Filing Attorney attests that all other
Signatories listed, and on whose behalf
the filing is submitted, concur in the filing’s
content and have authorized the filing.
See N.D. Cal. Civ. L.R. 5-1(i)(3).

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D
RDERE
S SO O
IT I

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NO

seph C.

Spero

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A

H

ER

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Judge Jo

R NIA

Dated: April 18, 2016

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UNIT
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S DISTRICT
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D IS T IC T O
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PROOF OF SERVICE
{00590845.DOCX }

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STATE OF CALIFORNIA, COUNTY OF ORANGE

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Ali Rankankan v. JPMorgan Chase Bank, N.A.
USDC Northern District (Oakland) Case No.: 4:16-cv-01694

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I am employed in the County of Orange, State of California. I am over the age
of 18 years and not a party to the within action. My business address is Parker
Ibrahim & Berg LLC, 695 Town Center Drive, 16th Floor, Costa Mesa,
California 92626.
On April 11, 2016, I served the foregoing document described as JOINT
STIPULATION TO EXTEND DATE TO FILE RESPONSIVE PLEADING TO
PLAINTIFF’S COMPLAINT on the interested parties in this action.
by placing the original and/or a true copy thereof enclosed in (a) sealed
envelope(s), addressed as follows:
SEE ATTACHED SERVICE LIST
BY REGULAR MAIL: I deposited such envelope in the mail at 695 Town Center Drive,
16th Floor, Costa Mesa, California 92626. The envelope was mailed with postage thereon
fully prepaid.
I am “readily familiar” with the firm’s practice of collection and processing correspondence
for mailing. It is deposited with the U.S. Postal Service on that same day in the ordinary
course of business. I am aware that on motion of the party served, service is presumed invalid
if postal cancellation date or postage meter date is more than one (1) day after date of deposit
for mailing in affidavit.
BY THE ACT OF FILING OR SERVICE, THAT THE DOCUMENT WAS
PRODUCED ON PAPER PURCHASED AS RECYCLED.
BY FACSIMILE MACHINE: I Tele-Faxed a copy of the original document to the above
facsimile numbers.
BY OVERNIGHT MAIL: I deposited such documents at the Golden State Overnight or
Federal Express Drop Box located at 695 Town Center Drive, 16th Floor, Costa Mesa,
California 92626. The envelope was deposited with delivery fees thereon fully prepaid.
BY CM/ECF ELECTRONIC DELIVERY: In accordance with the registered case
participants and in accordance with the procedures set forth at the Court’s website
www.ecf.cacd.uscourts.gov

(Federal) 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.
Executed on April 11, 2016, at Costa Mesa, California.

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/s/ Katherine Edwards

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Katherine Edwards

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{00590845.DOCX }

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SERVICE LIST

Ali Rankankan v. JPMorgan Chase Bank, N.A.
USDC Northern District (Oakland) Case No.: 4:16-cv-01694

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Thomas Eastridge. Esq/
Law Offices of Thomas Eastridge
1425 Leimert Blvd., Suite 400
Oakland, CA 94602

T 510.530.1700
F 510.530.8067
Attorney for Plaintiff
Ali Rankankan

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Richard J. Reynolds, Esq.
Burk, Williams & Sorensen, LLP
1851 East First St., Suite 1550
Santa Ana, CA 92705-4067

Attorneys for Defendant
MTC Financial dba Trustee Corps

Tanya C. McCullah, Esq.
Zieve, Brodnax & Steele, LLP
30 Corporate Park, Suite 450
Irvine, CA 92606

Attorneys for Defendant
U.S. Bank

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VIA OVERNIGHT
Chief Magistrate Judge Joseph C. Spero
San Francisco Courthouse, Courtroom G – 15th Flr
450 Golden Gate Avenue
San Francisco, CA 94102

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{00590845.DOCX }

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