David Strong v. Experian Information Solutions, Inc. et al

Filing 20

STIPULATION AND ORDER RE 19 TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND TO INITIAL COMPLAINT. Signed by Judge Richard Seeborg on 3/17/17. (cl, COURT STAFF) (Filed on 3/17/2017)

1 MARY KATE SULLIVAN (State Bar No. 180203)
[e-mail]
2 ALISA A. GIVENTAL (State Bar No. 273551)
[e-mail]
3 SEVERSON & WERSON
A Professional Corporation
4 One Embarcadero Center, Suite 2600
San Francisco, California 94111
5 Telephone: [phone]
Facsimile: [phone]
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7 Attorneys for Defendants
WELLS FARGO BANK, N.A.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA — SAN FRANCISCO DIVISION

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12 DAVID STRONG,

Case No. 3:17-CV-00503-RS

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SECOND STIPULATION TO EXTEND
TIME FOR DEFENDANT WELLS
FARGO BANK, N.A. TO RESPOND TO
INITIAL COMPLAINT AND
[PROPOSED] ORDER

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Plaintiff,
vs.

15 EXPERIAN INFORMATION SOLUTIONS,
INC.; WELLS FARGO BANK, NATIONAL
16 ASSOCIATION; TD BANK USA,
NATIONAL ASSOCIATION AND DOES 1
17 THROUGH 100 INCLUSIVE,
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Defendants.

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Plaintiff DAVID STRONG (“Plaintiff”) and defendant WELLS FARGO BANK, N.A.,

21 (“Defendant”), hereby stipulate as follows:
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RECITALS
1.

Plaintiff filed this action against Defendant on January 31, 2017 and served

24 Defendant on February 2, 2017.
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2.

Defendant’s initial deadline to respond to the Complaint was February 23, 2017

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3.

Plaintiff and Defendant agreed to extend the time for Defendant to respond to the

27 Complaint up to and including March 27, 2017, so that Defendant could have additional time to
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3:17-CV-00503-RS
1
SECOND STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND
TO INITIAL COMPLAINT AND [PROPOSED] ORDER

08999.0199/10542216.1

1 investigate this matter and the parties may explore the possibility of settlement.
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4.

On or about March 15, 2017, Plaintiff informed Defendant that he intended to file a

3 First Amended Complaint in the Action no later than April 7, 2017. Accordingly, Plaintiff and
4 Defendant agreed that Defendant’s deadline to respond to the complaint should be further
5 extended to, April 28, 2017, which is 21 days from the anticipated date of Plaintiff filing an
6 amended complaint.
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This change in deadline will not alter the date of any event or any deadline already fixed

8 by Court order, local rules, or the Federal Rules of Civil Procedure.
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THEREFORE, the parties stipulate as follows:

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STIPULATION
1.

The deadline for Defendant to respond to the Complaint or any amended complaint

12 filed by April 7, 2017, shall be continued to April 28, 2017.
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2.

This change in deadline will not alter the date of any event or any deadline already

14 fixed by Court order, local rules, or the Federal Rules of Civil Procedure.
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IT IS SO STIPULATED.

16 DATED: March 17, 2017

SAGARIA LAW, P.C.

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By:

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/s/ Elliot W. Gale
Elliot W. Gale

Attorneys for Plaintiff DAVID STRONG

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DATED: March 17, 2017

SEVERSON & WERSON
A Professional Corporation

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By:

/s/ Alisa A. Givental
Alisa A. Givental

Attorneys for Defendants WELLS FARGO BANK,
N.A.

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Pursuant to Local Rule 5-1(i)(3), I -- Alisa A. Givental – attest that concurrence in the filing of
28 this document has been obtained from Elliot W. Gale. /s/ Alisa A. Givental
3:17-CV-00503-RS
08999.0199/10542216.1
2
SECOND STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND
TO INITIAL COMPLAINT AND [PROPOSED] ORDER

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2

[PROPOSED] ORDER
Pursuant to the stipulation of the parties and good cause appearing, Wells Fargo Bank,

3 N.A.’s deadline to respond to plaintiff David Strong’s Complaint or any amended complaint filed
4 by April 7, 2017, is hereby continued to April 28, 2017. No other deadlines shall be affected by
5 this Order.
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IT IS SO ORDERED.

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8 DATED: 3/17/17
HONORABLE RICHARD SEEBORG
UNITED STATES JUDGE

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3:17-CV-00503-RS
3
SECOND STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND
TO INITIAL COMPLAINT AND [PROPOSED] ORDER

08999.0199/10542216.1