Raifman et al v. Wachovia Securities, LLC et al

Filing 152

ORDER by Judge ARMSTRONG granting 150 Motion for Leave to File Excess Pages (lrc, COURT STAFF) (Filed on 5/7/2013)

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1 2 3 4 5 6 7 8 9 10 11 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 DAVID A. PICON (Pro Hac Vice) dpicon@proskauer.com PROSKAUER ROSE LLP Eleven Times Square New York, NY 10036-8299 Telephone: 212-969-3000 Facsimile: 212-969-2900 Attorneys for Defendant Wachovia Securities, LLC, n/k/a Wells Fargo Advisors, LLC 12 UNITED STATES DISTRICT COURT 13 NORTHERN DISTRICT OF CALIFORNIA - OAKLAND DIVISION 14 15 16 17 18 19 20 21 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 INTERVIVOS TRUST and as beneficiaries of the PALLADIAN TRUST; GEKKO HOLDINGS, LLC; 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 22 23 24 Case No. C 11-02885 SBA STIPULATION TO EXCEED MOTION PAGE LIMIT Action Filed: April 1, 2011 [Removed from California State Court] Hon. Saundra B. Armstrong Plaintiffs, v. WACHOVIA SECURITIES, LLC, N/K/A WELLS FARGO ADVISORS, LLC, 25 Defendant. 26 27 28 Case No. C 11-02885 SBA STIPULATION TO EXCEED MOTION PAGE LIMIT 1 Whereas, on May 2, 2013, Plaintiffs Gregory R. Raifman and Susan Raifman, husband and 2 wife, individually and on behalf of their marital community and as Trustees of The Raifman Family 3 Revocable Inter Vivos Trust, as beneficiaries of The Palladian Trust, and as sole members of Gekko 4 Holdings, LLC; Edward and Lorraine Kurata, husband and wife; James Loomis; Jeffrey Chou; and 5 Bruce Cardinal, as Trustee of the Robert J. Cardinal Grandchildren’s Trust, and as Trustee of the 6 Marion I. Cardinal Trust, and as Managing Member of Redbird Investment Group, LLC 7 (collectively, “Plaintiffs”), filed their Third Amended Complaint (“TAC”) in this action, pursuant to 8 an agreement between the parties and the Order of this Court; 9 10 11 12 13 14 Whereas the parties met and conferred but were unable to reach a resolution on a number of the issues discussed regarding allegations made in the TAC; Whereas counsel for Defendant Wachovia Securities, LLC (“Defendant”) informed Plaintiffs’ counsel that Defendant intends to file a Motion to Dismiss the TAC; and Whereas Defendant believes it needs more than the 15 pages permitted by the Court’s Standing Order to fully and properly address all issues raised in Plaintiffs’ TAC; 15 NOW, THEREFORE, the parties, through their counsel, hereby stipulate and agree, pursuant 16 to Local Rule 7-11(a), that Defendant may exceed the 15 page limit on its Motion by five pages, and 17 file a Motion to Dismiss not to exceed 20 pages. 18 DATED: May 6, 2013 19 20 21 /s/ Ronald E. Wood Ronald E. Wood 22 Attorneys for Defendant 23 24 25 26 27 28 DAVID A. PICON RONALD E. WOOD JENNIFER L. ROCHE PROSKAUER ROSE LLP DATED: May 6, 2013 TOD ARONOVITZ BARBARA PEREZ ANDREW ZELMANOWITZ /s/ Tod Aronovitz TOD ARONOVITZ Attorney for Plaintiffs 2 STIPULATION TO EXCEED MOTION PAGE LIMIT 1 PURSUANT TO STIPULATION, IT IS SO ORDERED. 2 3 DATED: 5/7/13_____________ 4 _________________________________ Hon. Saundra J. Armstrong United States District Judge 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATION TO EXCEED MOTION PAGE LIMIT

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