Otero v. Experian Information Solutions, Inc. et al
Filing
32
STIPULATION AND ORDER re 29 STIPULATION WITH PROPOSED ORDER Stipulation to Extend Time for Defendant Wells Fargo Bank, N.A. to Respond to First Amended Complaint and [Proposed] Order filed by Wells Fargo Bank, National Association. Signed by Judge Edward M. Chen on 5/26/17. (bpfS, COURT STAFF) (Filed on 5/26/2017)
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
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
07685.1803/10750342.1
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 indicated her
5 intention to do so in the near future. Accordingly, the parties agreed to extend Defendant’s
6 response deadline to May 26, 2017.
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.
Plaintiff filed the First Amended Complaint on April 28, 2017. Based on the
11 allegations in the First Amended Complaint and informal discovery, Plaintiff and Defendant are
12 exploring settlement and stipulate that Defendant’s deadline to respond to the First Amended
13 Complaint shall be extended by another 31 days, up to and including June 26, 2017.
14
8.
This change in deadline will not alter the date of any event or any deadline already
15 fixed by Court order, local rules, or the Federal Rules of Civil Procedure.
16
THEREFORE, the parties stipulate as follows:
17
STIPULATION
18
1.
The deadline for Defendant to respond to the anticipated First Amended Complaint
19 or, in the event no amended complaint is filed, the initial complaint, shall be up to and including
20 June 26, 2017.
21
2.
This change in deadline will not alter the date of any event or any deadline already
22 fixed by Court order, local rules, or the Federal Rules of Civil Procedure.
23
IT IS SO STIPULATED.
24 DATED: May 25, 2017
SAGARIA LAW, P.C.
25
26
By:
27
28
07685.1803/10750342.1
/s/ Elliot W. Gale
Elliot W. Gale
Attorneys for Plaintiff EARLENE OTERO
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
1
2
DATED: May 25, 2017
SEVERSON & WERSON
A Professional Corporation
3
4
By:
/s/ Alisa A. Givental
Alisa A. Givental
5
6
Attorneys for Defendants WELLS FARGO BANK,
N.A.
7
8
Pursuant to Local Rule 5-1(i)(3), I -- Alisa A. Givental – attest that concurrence in the filing of
9 this document has been obtained from Elliot W. Gale. /s/ Alisa A. Givental
10
[PROPOSED] ORDER
11
12
Pursuant to the stipulation of the parties and good cause appearing, Wells Fargo Bank,
13 N.A.’s deadline to respond to the anticipated First Amended Complaint or, in the event no
14 amended complaint is filed, the initial complaint, shall be up to and including June 26, 2017. No
15 other deadlines shall be affected by this Order.
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UNITED STATES JUDGE
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5/26/17
18 DATE: _______________
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IT IS SO ORDERED.
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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
07685.1803/10750342.1
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