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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RONALD E. WOOD, SBN 133854
[e-mail]
JENNIFER L. ROCHE, SBN 254538
[e-mail]
PROSKAUER ROSE LLP
2049 Century Park East, Suite 3200
Los Angeles, CA 90067-3206
Telephone: [phone]
Facsimile: 310-557-2193
DAVID A. PICON (Pro Hac Vice)
[e-mail]
PROSKAUER ROSE LLP
Eleven Times Square
New York, NY 10036-8299
Telephone: [phone]
Facsimile: 212-969-2900
Attorneys for Defendant
Wachovia Securities, LLC,
n/k/a Wells Fargo Advisors, LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA - OAKLAND DIVISION

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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

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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,

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Defendant.
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Case No. C 11-02885 SBA
STIPULATION TO EXCEED MOTION PAGE LIMIT

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Whereas, on May 2, 2013, Plaintiffs Gregory R. Raifman and Susan Raifman, husband and

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wife, individually and on behalf of their marital community and as Trustees of The Raifman Family

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Revocable Inter Vivos Trust, as beneficiaries of The Palladian Trust, and as sole members of Gekko

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Holdings, LLC; Edward and Lorraine Kurata, husband and wife; James Loomis; Jeffrey Chou; and

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Bruce Cardinal, as Trustee of the Robert J. Cardinal Grandchildren’s Trust, and as Trustee of the

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Marion I. Cardinal Trust, and as Managing Member of Redbird Investment Group, LLC

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(collectively, “Plaintiffs”), filed their Third Amended Complaint (“TAC”) in this action, pursuant to

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an agreement between the parties and the Order of this Court;

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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;

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NOW, THEREFORE, the parties, through their counsel, hereby stipulate and agree, pursuant

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to Local Rule 7-11(a), that Defendant may exceed the 15 page limit on its Motion by five pages, and

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file a Motion to Dismiss not to exceed 20 pages.

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DATED: May 6, 2013

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/s/ Ronald E. Wood
Ronald E. Wood

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Attorneys for Defendant

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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

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STIPULATION TO EXCEED MOTION PAGE LIMIT

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PURSUANT TO STIPULATION, IT IS SO ORDERED.
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DATED: 5/7/13_____________

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_________________________________
Hon. Saundra J. Armstrong
United States District Judge

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STIPULATION TO EXCEED MOTION PAGE LIMIT