Raifman et al v. Wachovia Securities, LLC et al

Filing 135

STIPULATION AND ORDER re 133 STIPULATION WITH PROPOSED ORDER re 131 Amended Complaint, filed by Bruce Cardinal, Helicon Investments, Ltd., Susan Raifman, Gregory R. Raifman, Lorraine Kurata, Wachovia Securities, LLC, Edward Kurata, Jeffrey Chou, Wells Fargo Advisors, LLC, James Loomis. Signed by Judge ARMSTRONG on 3/27/13. (lrc, COURT STAFF) (Filed on 3/27/2013)

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1 2 3 4 5 6 7 RONALD E. WOOD, SBN 133854 rwood@proskauer.com JENNIFER L. ROCHE, SBN 254538 jroche@proskauer.com PROSKAUER ROSE LLP 2049 Century Park East, Suite 3200 Los Angeles, CA 90067-3206 Telephone: 310-557-2900 Facsimile: 310-557-2193 Attorneys for Defendant Wachovia Securities, LLC n/k/a Wells Fargo Advisors, LLC 8 9 UNITED STATES DISTRICT COURT 10 NORTHERN DISTRICT OF CALIFORNIA 11 OAKLAND DIVISION 12 13 14 15 16 17 18 19 20 21 22 23 24 Case No. C 11-02885 SBA GREGORY R. RAIFMAN and SUSAN RAIFMAN, husband and wife, individually and on behalf of their marital community and as Trustees of the RAIFMAN FAMILY REVOCABLE INTER VIVOS TRUST and as beneficiaries of the PALLADIAN TRUST; GEKKO HOLDINGS, LLC, and HELICON INVESTMENTS, LTD; EDWARD and LORRAINE KURATA, as husband and wife; JAMES LOOMIS; JEFFREY CHOU; and BRUCE CARDINAL, as Trustee of the ROBERT J. CARDINAL GRANDCHILDREN’S TRUST, and the MARION I. CARDINAL TRUST, and as Managing Member of REDBIRD INVESTMENT GROUP, LLC., STIPULATION TO ENLARGE DEFENDANT’S TIME TO RESPOND TO PLAINTIFFS’ SECOND AMENDED COMPLAINT, PLAINTIFFS’ TIME TO OPPOSE ANY MOTION MADE PURSUANT TO FRCP 12(b) AND DEFENDANT’S TIME TO REPLY Hon. Saundra B. Armstrong Plaintiffs, v. WELLS FARGO ADVISORS, LLC, successor in interest to WACHOVIA SECURITIES, LLC; and WACHOVIA SECURITIES, LLC, Defendants. 25 26 WHEREAS, on March 19, 2013, Plaintiffs, Gregory R. Raifman and Susan Raifman, 27 husband and wife, individually and on behalf of their marital community and as Trustees of Plaintiff, 28 The Raifman Family Revocable Inter Vivos Trust, as beneficiaries of Plaintiff, The Palladian Trust, 1 Case No. C 11-02885 SBA STIPULATION TO ENLARGE DEFENDANT’S TIME TO RESPOND TO PLAINTIFFS’ SECOND AMENDED COMPLAINT, PLAINTIFFS’ TIME TO OPPOSE ANY MOTION MADE PURSUANT TO FRCP 12(b) AND DEFENDANT’S TIME TO REPLY 1 1 2 2 3 3 4 4 5 5 6 6 7 7 8 8 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 26 26 27 27 28 28 as sole members of Gekko Holdings, Ltd. and as assignees in interest and beneficial owners of Plaintiff, Helicon Investments, Ltd.; Edward and Lorraine Kurata, husband and wife; James Loomis; Jeffrey Chou and Bruce Cardinal, as Trustee of the Robert J. Cardinal Grandchildren’s Trust, and as Trustee of the Marion I. Cardinal Trust, and as Managing Member of Redbird Investment Group, LLC. (collectively, “Plaintiffs”), filed their Second Amended Complaint (“SAC”) in this action; WHEREAS, Defendant Wachovia Securities, LLC n/k/a Wells Fargo Advisors, LLC’s (“Defendant”) response to the SAC is due on April 2, 2013, pursuant to Federal Rule of Civil Procedure 15(a)(3); WHEREAS, Plaintiffs’ opposition to any motion Defendant may make pursuant to Federal Rule of Civil Procedure 12(b) would be due on April 16, 2013, pursuant to Local Rule 7-3; WHEREAS, Defendant’s reply to any opposition Plaintiffs may file would be due on April 23, 2013, pursuant to Local Rule 7-3; and WHEREAS, the parties have discussed and agreed that it is their mutual request to extend their respective filing dates, NOW, THEREFORE, the parties, through their counsel, hereby stipulate and agree, pursuant to Local Rule 6-1, that Defendant shall have up to and including April 16, 2013, to answer or otherwise respond to the SAC; that Plaintiffs shall have up to and including May 7, 2013 to file an opposition to any motion Defendant may file pursuant to Federal Rule of Civil Procedure 12(b); and that Defendant may thereafter have up to and including May 21, 2012 to file any reply to any opposition Plaintiffs may file. This Stipulation is agreed upon without prejudice to Plaintiffs’ right to seek an additional extension of time after Defendant’s filings and in the event that multiple motions are filed by Defendant. This extended briefing schedule will not alter the date of any event or deadline already fixed by Court order. Dated: March 25, 2013 RONALD E. WOOD JENNIFER L. ROCHE PROSKAUER ROSE LLP By: / s / Ronald E. Wood Ronald E. Wood Attorneys for Defendant 2 Case No. C 11-02885 SBA STIPULATION TO ENLARGE DEFENDANT’S TIME TO RESPOND TO PLAINTIFFS’ SECOND AMENDED COMPLAINT, PLAINTIFFS’ TIME TO OPPOSE ANY MOTION MADE PURSUANT TO FRCP 12(b) AND DEFENDANT’S TIME TO REPLY 1 1 2 2 3 3 4 4 5 5 6 6 7 7 8 8 9 9 10 10 11 11 12 12 13 13 14 14 15 15 16 16 17 17 18 18 19 19 20 20 21 21 22 22 23 23 24 24 25 25 26 26 27 27 28 28 Dated: March 25, 2013 Tod Aronovitz (Pro Hac Vice) Barbara Perez (Pro Hac Vice) Andrew Zelmanowitz (Pro Hac Vice) ARONOVITZ LAW By: / s / Tod Aronovitz Attorneys for Plaintiffs PURSUANT TO STIPULATION, IT IS SO ORDERED. Dated: 3/27/13 Hon. Saundra B. Armstrong United States District Judge 3 Case No. C 11-02885 SBA STIPULATION TO ENLARGE DEFENDANT’S TIME TO RESPOND TO PLAINTIFFS’ SECOND AMENDED COMPLAINT, PLAINTIFFS’ TIME TO OPPOSE ANY MOTION MADE PURSUANT TO FRCP 12(b) AND DEFENDANT’S TIME TO REPLY

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