Otero v. Experian Information Solutions, Inc. et al

Filing 25

STIPULATION AND ORDER re 23 STIPULATION WITH PROPOSED ORDER re 1 Complaint, TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND filed by Wells Fargo Bank, National Association. Signed by Judge Edward M. Chen on 5/1/17. (bpf, COURT STAFF) (Filed on 5/1/2017)

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

10
EARLENE OTERO,

Case No. 3:17-CV-00508-EMC

11
Plaintiff,
12
vs.
13

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

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

Defendant.

17
18

Plaintiff EARLENE OTERO (“Plaintiff”) and defendant WELLS FARGO BANK, N.A.

19 (“Defendant”), hereby stipulate as follows:
20

RECITALS

21

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 First Amended Complaint in the Action no later than April 7, 2017. Accordingly, Plaintiff and
3:17-CV-00508-EMC
08999.0205/10696894.1
1
STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND TO FIRST
AMENDED COMPLAINT AND [PROPOSED] ORDER

1 Defendant agreed that Defendant’s deadline to respond to the complaint should be further
2 extended to, April 28, 2017, which was 21 days from the anticipated date of Plaintiff filing an
3 amended complaint.
4

5.

Plaintiff did not file an amended Complaint by April 7, 2017, but anticipates filing

5 an amended complaint by April 28, 2017, rendering it appropriate for Defendant to wait until the
6 filing of the amended complaint prior to preparing a response.
7

6.

Plaintiff and Defendant stipulate that Defendant’s deadline to respond to the

8 anticipated First Amended Complaint or, in the event no amended complaint is filed, the initial
9 complaint, shall be up to and including May 26, 2017.
10

7.

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

11 fixed by Court order, local rules, or the Federal Rules of Civil Procedure.
12

THEREFORE, the parties stipulate as follows:

13

STIPULATION

14

1.

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

15 or, in the event no amended complaint is filed, the initial complaint, shall be up to and including
16 May 26, 2017.
17

2.

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

18 fixed by Court order, local rules, or the Federal Rules of Civil Procedure.
19

IT IS SO STIPULATED.

20 DATED: April 26, 2017
21

SAGARIA LAW, P.C.
B
B

22

By:

23
24

/s/ Elliot W. Gale
Elliot W. Gale

Attorneys for Plaintiff EARLENE OTERO

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26
27
28
3:17-CV-00508-EMC
2
STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND TO FIRST
AMENDED COMPLAINT AND [PROPOSED] ORDER

08999.0205/10696894.1

1 DATED: April 26, 2017
2

SEVERSON & WERSON
A Professional Corporation

3

B
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
10

13
14
15

N.A.’s deadline to respond to the anticipated First Amended Complaint or, in the event no
amended complaint is filed, the initial complaint, shall be up to and including May 26, 2017. No
other deadlines shall be affected by this Order.
IT IS SO ORDERED.

16

S

______________________________________
HONORABLE EDWARD M. CHEN
UNITED STATES JUDGE RDERED
O

UNIT
ED

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RT
U
O

17 DATE: _______________
5/1/17
18

S DISTRICT
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TA

O

IT IS S

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dwar
Judge E

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A

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en

d M. Ch

NO

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R NIA

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Pursuant to the stipulation of the parties and good cause appearing, Wells Fargo Bank,

FO

11

[PROPOSED] ORDER

N

F
D IS T IC T O
R

C

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3:17-CV-00508-EMC
3
STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND TO FIRST
AMENDED COMPLAINT AND [PROPOSED] ORDER

08999.0205/10696894.1