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

Filing 31

STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND. Signed by Judge Richard Seeborg on 4/28/17. (cl, COURT STAFF) (Filed on 4/28/2017)

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1 MARY KATE SULLIVAN (State Bar No. 180203) mks@severson.com 2 ALISA A. GIVENTAL (State Bar No. 273551) aag@severson.com 3 SEVERSON & WERSON A Professional Corporation 4 One Embarcadero Center, Suite 2600 San Francisco, California 94111 5 Telephone: (415) 398-3344 Facsimile: (415) 956-0439 6 Attorneys for Defendants 7 WELLS FARGO BANK, N.A. 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA — SAN FRANCISCO DIVISION 10 DAVID STRONG, Case No. 3:17-CV-00503-RS 11 STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND TO FIRST AMENDED COMPLAINT AND [PROPOSED] ORDER 12 Plaintiff, vs. 13 EXPERIAN INFORMATION SOLUTIONS, INC.; WELLS FARGO BANK, NATIONAL 14 ASSOCIATION; TD BANK USA, NATIONAL ASSOCIATION AND DOES 1 15 THROUGH 100 INCLUSIVE, Defendants. 16 17 18 Plaintiff DAVID STRONG (“Plaintiff”) and defendant WELLS FARGO BANK, N.A., 19 (“Defendant”), hereby stipulate as follows: 20 21 RECITALS 1. Plaintiff filed this action against Defendant on January 31, 2017 and served 22 Defendant on February 2, 2017. 23 2. Defendant’s initial deadline to respond to the Complaint was February 23, 2017 24 3. Plaintiff and Defendant agreed to extend the time for Defendant to respond to the 25 Complaint up to and including March 27, 2017, so that Defendant could have additional time to 26 investigate this matter and the parties may explore the possibility of settlement. 27 4. On or about March 15, 2017, Plaintiff informed Defendant that he intended to file a 28 3:17-CV-00503-RS 1 STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND TO FIRST AMENDED COMPLAINT AND [PROPOSED] ORDER 08999.0199/10696899.1 1 First Amended Complaint in the Action no later than April 7, 2017. Accordingly, Plaintiff and 2 Defendant agreed that Defendant’s deadline to respond to the complaint should be further 3 extended to, April 28, 2017, which was 21 days from the anticipated date of Plaintiff filing an 4 amended complaint. 5 5. Plaintiff did not file an amended Complaint by April 7, 2017, but anticipates filing 6 an amended complaint by April 28, 2017, rendering it appropriate for Defendant to wait until the 7 filing of the amended complaint prior to preparing a response. 8 6. Plaintiff and Defendant stipulate that Defendant’s deadline to respond to the 9 anticipated First Amended Complaint or, in the event no amended complaint is filed, the initial 10 complaint, shall be up to and including May 26, 2017. 11 7. This change in deadline will not alter the date of any event or any deadline already 12 fixed by Court order, local rules, or the Federal Rules of Civil Procedure. 13 THEREFORE, the parties stipulate as follows: 14 15 STIPULATION 1. The deadline for Defendant to respond to the anticipated First Amended Complaint 16 or, in the event no amended complaint is filed, the initial complaint, shall be up to and including 17 May 26, 2017. 18 2. This change in deadline will not alter the date of any event or any deadline already 19 fixed by Court order, local rules, or the Federal Rules of Civil Procedure. 20 IT IS SO STIPULATED. 21 DATED: April 26, 2017 SAGARIA LAW, P.C. 22 By: 23 /s/ Elliot W. Gale Elliot W. Gale 24 Attorneys for Plaintiff DAVID STRONG 25 26 27 28 3:17-CV-00503-RS 2 STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND TO FIRST AMENDED COMPLAINT AND [PROPOSED] ORDER 08999.0199/10696899.1 1 DATED: April 26, 2017 2 SEVERSON & WERSON A Professional Corporation 3 By: 4 /s/ Alisa A. Givental Alisa A. Givental 5 Attorneys for Defendants WELLS FARGO BANK, N.A. 6 7 8 Pursuant to Local Rule 5-1(i)(3), I -- Alisa A. Givental – attest that concurrence in the filing of this document has been obtained from Elliot W. Gale. /s/ Alisa A. Givental 9 [PROPOSED] ORDER 10 11 Pursuant to the stipulation of the parties and good cause appearing, Wells Fargo Bank, 12 N.A.’s deadline to respond to the anticipated First Amended Complaint or, in the event no 13 amended complaint is filed, the initial complaint, shall be up to and including May 26, 2017. No 14 other deadlines shall be affected by this Order. 15 IT IS SO ORDERED. 16 17 DATED: 4/28/17 18 HONORABLE RICHARD SEEBORG UNITED STATES JUDGE 19 20 21 22 23 24 25 26 27 28 3:17-CV-00503-RS 3 STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND TO FIRST AMENDED COMPLAINT AND [PROPOSED] ORDER 08999.0199/10696899.1

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