Peters v. Wells Fargo Bank, N.A.

Filing 29

STIPULATION AND ORDER re 28 STIPULATION WITH PROPOSED ORDER TO ENLARGE TIME FOR PLAINTIFF TO RESPOND TO MOTIONS, EXTEND REPLY TIME AND CONTINUE CMC filed by Michael Peters. Signed by Judge Jon S. Tigar on October 3, 2017. (wsn, COURT STAFF) (Filed on 10/3/2017)

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Robins Kaplan LLP
Michael F. Ram (SBN 104805)
[e-mail]
Susan S. Brown (SBN #287986)
[e-mail]
2440 West El Camino Real, Suite 100
Mountain View, CA 94040
Telephone: [phone]
Facsimile: 650 784 4041

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Epps Holloway DeLoach & Hoipkemier, LLC
Adam L. Hoipkemier [Admitted Pro Hac Vice]
[e-mail]
Kevin E. Epps [Admitted Pro Hac Vice]
[e-mail]
1220 Langford Drive, Bldg. 200
Watkinsville, GA 30677
Telephone: [phone]
Facsimile:
706 842 6750

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Attorneys for Plaintiff and Proposed Class

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United States District Court
Northern District of California

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA
MICHAEL PETERS, individually and on behalf of
all others similarly situated

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v.

Plaintiff(s)

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WELLS FARGO BANK, N.A.,

Case No. 3:17-cv-04367-JST
STIPULATION TO ENLARGE TIME
FOR PLAINTIFF TO RESPOND TO
MOTIONS AND EXTEND REPLY
TIME AND CONTINUE CMC

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Defendant(s).

Pursuant to Local Rule 6-2, Plaintiff Michael Peters (“Plaintiff”) and Defendant
Wells Fargo Bank, N.A. (“Wells Fargo”) respectfully submit the following Stipulation to

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Enlarge the Time for Plaintiff to respond to Defendant Wells Fargo Bank’s Motion to

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Transfer Venue, Motion to Dismiss Plaintiff’s First Amended Complaint, and Motion to

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Strike Plaintiff’s Amended Complaint (“Motions”), to provide a date for Defendant’s

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Replies in Support of those Motions, and to reschedule the Case Management

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Conference for the same date as the hearings on the pending Motions.
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Stipulation to Enlarge Time for Plaintiff to Respond to Motions and Extend Reply Time and Continue CMC
Case No.: 3-17-cv-04367-JST

RECITALS

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WHEREAS, Defendant filed its Motions on September 20, 2017;

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WHEREAS, Plaintiff’s current deadline to respond to all motions pursuant to the

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Local Rules is fourteen (14) days after the notice of motions were filed, or October 4,
2017;
WHEREAS, Plaintiff and his counsel require additional time to evaluate and
analyze the motions and to prepare responses;
WHEREAS, Defendant and its counsel anticipate requiring additional time to
evaluate Plaintiff’s oppositions and prepare responses;

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United States District Court
Northern District of California

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WHEREAS, the Case Management Conference is currently set for November 8,
2017 (D.E. 10);
WHEREAS, the hearing on the motions is currently set for December 7, 2017 and
accordingly, the stipulated extensions of time will not alter the date of any event or

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deadline already fixed by Court order. No party will be prejudiced by the short

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extensions;

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WHEREAS, in order to consolidate travel and convenience of the Parties and
Court, the Parties agree that the Case Management Conference be set for December 7,

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2017, the same day as the Motions are scheduled for argument.
STIPULATION

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THEREFORE, subject to Court approval, the Parties agree through their respective

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attorneys to the following:

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Stipulation to Enlarge Time for Plaintiff to Respond to Motions and Extend Reply Time and Continue CMC
Case No.: 3-17-cv-04367-JST

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three (3) weeks to October 25, 2017.

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Plaintiff’s time to respond to the three pending motions shall be extended

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Defendant’s replies to the three motions shall be due on November 13,
2017.

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defenses of all parties.

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5.

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2017. December 14, 2017.

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United States District Court
Northern District of California

The Case Management Conference currently set for November 8, 2017 will
be moved to the date and time of the motion hearings on December 7,

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This stipulation is without prejudice to the rights, claims, arguments, and

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The motion hearings will be moved to December 14, 2017.

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All other signatories listed, and on whose behalf the filing is submitted, concur in the

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filing’s content and have authorized the filing.
DATED: September 29, 2017
Respectfully submitted,

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Robins Kaplan LLP

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By: /s/ Michael F. Ram
Michael F. Ram
Robins Kaplan, LLP
2440 W El Camino Real, Suite #100
Mountain View, CA 94040

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Adam Hoipkemier
Epps, Holloway, DeLoach &
Hoipkemier, LLC
6 Concourse Parkway #2920
Atlanta, Georgia 30328
Attorneys for Plaintiff, Michael Peters

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Stipulation to Enlarge Time for Plaintiff to Respond to Motions and Extend Reply Time and Continue CMC
Case No.: 3-17-cv-04367-JST

Case 3:17-cv-04367-JST Document 28 Filed 10/03/17 Page 4 of 4

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/s/ K. Isaac DeVyver
K. Isaac DeVyver
McGuireWoods
Tower Two-Sixty
260 Forbes Avenue, Suite 1800
Pittsburgh, PA 15222-3142

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Counsel for Wells Fargo Bank, N.A

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SO ORDERED,

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DATED:

October 3, 2017
___________________

__________________________________
United States District Judge

United States District Court
Northern District of California

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Stipulation to Enlarge Time for Plaintiff to Respond to Motions and Extend Reply Time and Continue CMC
Case No.: 3-17-cv-04367-JST