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

Filing 36

STIPULATION AND ORDER RE 35 for Extension of Time for Defendant Wells Fargo Bank, N.A. to Respond to First Amended Complaint. Signed by Judge Richard Seeborg on 5/26/17. (cl, COURT STAFF) (Filed on 5/26/2017)

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]
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,
16

Defendants.

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18

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

19 (“Defendant”), hereby stipulate as follows:
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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

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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

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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

08999.0199/10750310.1

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 indicated his

6 intention to do so in the near future. Accordingly, the parties agreed to extend Defendant’s
7 response deadline to May 26, 2017.
8

6.

Plaintiff filed the First Amended Complaint on April 28, 2017. Based on the

9 allegations in the First Amended Complaint and informal discovery, Plaintiff and Defendant are
10 exploring settlement and stipulate that Defendant’s deadline to respond to the First Amended
11 Complaint shall be extended by another 31 days, up to and including June 26, 2017.
12

7.

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

13 fixed by Court order, local rules, or the Federal Rules of Civil Procedure.
14

THEREFORE, the parties stipulate as follows:

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16

STIPULATION
1.

The deadline for Defendant to respond to the anticipated First Amended Complaint

17 or, in the event no amended complaint is filed, the initial complaint, shall be up to and including
18 June 26, 2017.
19

2.

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

20 fixed by Court order, local rules, or the Federal Rules of Civil Procedure.
21

IT IS SO STIPULATED.

22 DATED: May 25, 2017

SAGARIA LAW, P.C.

23
By:

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/s/ Elliot W. Gale
Elliot W. Gale

25
Attorneys for Plaintiff DAVID STRONG
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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

08999.0199/10750310.1

1 DATED: May 25, 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

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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 June 26, 2017. No
14 other deadlines shall be affected by this Order.
15

IT IS SO ORDERED.

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17 DATED: 5/26/17
18

HONORABLE RICHARD SEEBORG
UNITED STATES JUDGE

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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

08999.0199/10750310.1