Diaz et al v. Wells Fargo Bank, National Association

Filing 11

AMENDED Second Stipulation and Order to Extend Time for Defendant Wells Fargo Bank, N.A. to Respond to the Complaint. Deadline for defendant to respond to the complaint is extended to 01/12/2018. Signed by Judge Laurel Beeler on 01/03/2018. (ejkS, COURT STAFF) (Filed on 1/3/2018)

1 MARY KATE SULLIVAN (State Bar No. 180203)
[e-mail]
2 ALISA A. GIVENTAL (State Bar No. 273551)
[e-mail]
3 TARA MOHSENI (State Bar No. 313080)
[e-mail]
4 SEVERSON & WERSON
A Professional Corporation
5 One Embarcadero Center, Suite 2600
San Francisco, California 94111
6 Telephone: [phone]
Facsimile: [phone]
7
Attorneys for DEFENDANT
8 WELL FARGO BANK, N.A.
9
UNITED STATES DISTRICT COURT
10
NORTHERN DISTRICT OF CALIFORNIA
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RICARDO DIAZ AND MARIA ELENA
12 DIAZ,
13

Plaintiffs,

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vs.

Case No. 3:17-cv-06968-LB
SECOND STIPULATION TO EXTEND
TIME FOR DEFENDANT WELLS
FARGO BANK, N.A. TO RESPOND TO
THE COMPLAINT; [PROPOSED]
ORDER

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WELLS FARGO BANK, NATIONAL
16 ASSOCIATION, and DOES 1 through 20,
inclusive,
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Defendants.
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19

The Hon. Magistrate Judge Laurel Beeler
Action Filed:

November 6, 2017

Plaintiffs Ricardo Diaz and Maria Elena Diaz (“Plaintiffs”) and defendant WELLS

20 FARGO BANK, N.A. (“Defendant”), hereby stipulate as follows:
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RECITALS

22

1.

Whereas, Plaintiffs filed this action against Defendant in the Superior Court of

23 California, County of Contra Costa on November 3, 2017 and served Defendant on November 6,
24 2017.
25

2.

Whereas, Defendant removed the state court action to this Court on December 6,

27

3.

Whereas, Defendant’s deadline to respond to the complaint is December 13, 2017.

28

4.

26 2017.

Whereas, in order to evaluate Plaintiffs’ claims and explore early resolution of this
3:17-cv-06968-LB
55002.0543/11034527.1
1
SECOND STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND
TO THE COMPLAINT; [PROPOSED] ORDER

1 action, the parties agreed to extend Defendant’s response deadline to January 3, 2018.
2

5.

Whereas, Defendant is continuing its investigation into the allegations in the

3 Complaint and requested, and Plaintiff agreed, to an additional extension for the response to the
4 Complaint to be filed on or before January 12, 2018.
5

6.

Whereas, this is the second request for an extension in this action. No other

6 deadlines will be affected by this stipulation, as no other deadlines have yet been set by the Court.
7

7.

In light of the foregoing, the parties therefore stipulate and agree that Defendant

8 shall have through and including January 12, 2018 to respond to the complaint.
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IT IS SO STIPULATED.

10 DATED: January 2, 2018
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SEVERSON & WERSON
A Professional Corporation

12
By:

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/s/ Alisa A. Givental
Alisa A. Givental

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Attorneys for DEFENDANTS WELLS FARGO BANK,
N.A.

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16
17 DATED: January 2, 2018

ALBERT E. CORDOVA, APC

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19

By:

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/s/ Albert E. Cordova
Albert E. Cordova

Attorneys for Plaintiff RICARDO DIAZ AND MARIA
ELENA DIAZ

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22

23 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 Albert E. Cordova. /s/ Alisa A. Givental
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3:17-cv-06968-LB
2
SECOND STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND
TO THE COMPLAINT; [PROPOSED] ORDER

55002.0543/11034527.1

1
2

[PROPOSED] ORDER
Pursuant to the stipulation of the parties and good cause appearing, Wells Fargo Bank,

3 N.A.’s deadline to respond to plaintiff Lana Imes’s First Amended Complaint is hereby continued
January 12, 2018
4 to July 26, 2017. No other deadlines shall be affected by this Order.
5

IT IS SO ORDERED.

6
January 3, 2018
7 DATE: _______________
8

______________________________________
MAGISTRATE JUDGE LAUREL BEELER

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3:17-cv-06968-LB
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SECOND STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND
TO THE COMPLAINT; [PROPOSED] ORDER

55002.0543/11034527.1