Greene v. Wells Fargo Bank, N.A.

Filing 20

ORDER GRANTING 19 STIPULATION TO EXTEND BRIEFING DEADLINES RE: WELLS FARGO'S MOTION TO DISMISS COMPLAINT. Opposition due by 2/6/2015. Replies due by 2/13/2015. Signed by Judge JEFFREY S. WHITE on 1/28/15. (jjoS, COURT STAFF) (Filed on 1/28/2015)

A NGLIN F LEWELLING R ASMUSSEN C AMPBELL & T RYTTEN LLP

Case4:15-cv-00048-JSW Document19 Filed01/27/15 Page1 of 4

1 Robert A. Bailey (# 214688)
[e-mail]
2 Christine Hehir (# 201969)
[e-mail]
3 ANGLIN, FLEWELLING, RASMUSSEN,
CAMPBELL & TRYTTEN LLP
4 199 South Los Robles Avenue, Suite 600
Pasadena, California 91101-2459
5 Telephone: [phone]
Facsimile: [phone]
6
Attorneys for Defendant WELLS FARGO
7 BANK, N.A., successor by merger with
Wells Fargo Bank Southwest, N.A., f/k/a
8 Wachovia Mortgage, FSB, f/k/a World
Savings Bank, FSB (“Wells Fargo”)
9
10 Aldon L. Bolanos (SBN 233915)
[e-mail]
11 Law Offices of Aldon L. Bolanos
Seven-Hundred “E” Street
12 Sacramento, California 95814
Tel: [phone]
13 Fax: [phone]
14 Attorney for Plaintiff ROSEMARY GREENE
15
UNITED STATES DISTRICT COURT
16
NORTHERN DISTRICT OF CALIFORNIA – OAKLAND DIVISION
17
18
CASE NO.: 4:15-CV-00048-JSW

Rosemary Greene,
19

[The Honorable Jeffrey S. White]
Plaintiff,

20

JOINT STIPULATION IN SUPPORT OF
JOINT REQUEST TO EXTEND
BRIEFING DEADLINES RE: WELLS
FARGO’S MOTION TO DISMISS
PLAINTIFF’S COMPLAINT (DOC. NO.
12)

21
v.
22
23
24 Wells Fargo Bank, N.A.,

Date:
Time:
Ctrm:

25
Defendants.
26

March 13, 2015
9:00 a.m.
5, 2nd Floor (Oakland
Courthouse)

27
28
93000/FR1513/01070185-3

1

CASE NO.: 4:15-CV-00048-JSW
JOINT STIPULATION TO EXTEND BRIEFING
DEADLINES TO MOT. TO DISMISS COMPL.

Case4:15-cv-00048-JSW Document19 Filed01/27/15 Page2 of 4

1 TO THIS HONORABLE COURT:
2

Plaintiff Rosemary Greene (“Plaintiff”), and defendant WELLS FARGO BANK, N.A.,

3 successor by merger with Wells Fargo Bank Southwest, N.A., f/k/a Wachovia Mortgage, FSB,
4 f/k/a World Savings Bank, FSB, through their counsel of record, present the following
5 stipulation in support of their request to extend the briefing deadlines re: Wells Fargo’s motion to
6 dismiss plaintiff’s complaint.
RECITALS

A NGLIN F LEWELLING R ASMUSSEN C AMPBELL & T RYTTEN LLP

7
8

1.

WHEREAS, Plaintiff filed her complaint in the Alameda Superior Court on

9 December 11, 2014 and Wells Fargo was personally served on December 17, 2014;
10

2.

WHEREAS, Defendant Wells Fargo removed the action on January 6, 2015

11 (Document No. 1);
12

3.

WHEREAS, Defendant Wells Fargo filed a Motion to Dismiss Plaintiff’s

13 Complaint on January 13, 2015 (Document No. 12);
14

4.

WHEREAS, pursuant to L.R. 7-3, plaintiff’s response is due no later than January

15 27, 2015 and Wells Fargo’s reply is due no later than seven days after January 27, 2015, or
16 February 3, 2015;
17

5.

WHEREAS, the case was reassigned to Hon. Jeffrey S. White pursuant to Order

18 filed January 23, 2015 (Document No. 16);
19

6.

WHEREAS, pursuant to the Order, the Motion was re-noticed with the Briefing

20 schedule remaining unchanged. (Document No. 18);
21

7.

WHEREAS, upon the Renotice of the Complaint (Document No. 18) a new

22 response date was erroneously generated indicating plaintiff’s response was due on February 6,
23 2015 and Wells Fargo’s reply due no later than February 13, 2015;
24

8.

WHEREAS, the Parties agree to extend the deadline for plaintiff’s response from

25 January 27, 2015 to February 6, 2015;
26

9.

WHEREAS, Wells Fargo’s reply will be due no later than February 13, 2015;

27

10.

WHEREAS, this stipulation waives no rights of either Party;

28

11.

WHEREAS, the Parties have not previously stipulated to, requested, or granted.

93000/FR1513/01070185-3

2

CASE NO.: 4:15-CV-00048-JSW
JOINT STIPULATION TO EXTEND BRIEFING
DEADLINES TO MOT. TO DISMISS COMPL.

Case4:15-cv-00048-JSW Document19 Filed01/27/15 Page3 of 4

1 an extension of the briefing deadlines to the motion to dismiss the complaint.
STIPULATION

2
3

IT IS HEREBY STIPULATED that the deadline for Plaintiff’s response to the motion

4 to dismiss complaint is extended from January 27, 2015 to February 6, 2015 and Wells Fargo’s
5 reply to the opposition will be due no later than February 13, 2015.
6

A NGLIN F LEWELLING R ASMUSSEN C AMPBELL & T RYTTEN LLP

7 Dated: January 27, 2015

LAW OFFICES OF ALDON BOLANOS

8
By:

/s/ Aldon L. Bolanos
Aldon L. Bolanos
[e-mail]
Attorney for Plaintiff ROSEMARY GREENE

9
10
11
12
13

Dated: January 27, 2015

ANGLIN, FLEWELLING, RASMUSSEN,
CAMPBELL & TRYTTEN LLP

14
By:

/s/ Christine Hehir
Christine Hehir
[e-mail]
Attorneys for Defendant WELLS FARGO BANK,
N.A., successor by merger with Wells Fargo Bank
Southwest, N.A., f/k/a Wachovia Mortgage, FSB,
f/k/a World Savings Bank, FSB (“Wells Fargo”)

15
16
17
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19
20

ATTESTATION PURSUANT TO GENERAL ORDER 45

21

I, E. Christine Hehir, attest that concurrence in the filing of this document has been

22 obtained from each signatory. I declare under penalty of perjury under the laws of the United
23 States of America that the foregoing is true and correct. Executed this day of January 27, 2015.
By:

24

/s/ E. Christine Hehir

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93000/FR1513/01070185-3

3

CASE NO.: 4:15-CV-00048-JSW
JOINT STIPULATION TO EXTEND BRIEFING
DEADLINES TO MOT. TO DISMISS COMPL.

Case4:15-cv-00048-JSW Document19 Filed01/27/15 Page4 of 4

CERTIFICATE OF SERVICE

1
2

I, the undersigned, declare that I am over the age of 18 and am not a party to this action.
3 I am employed in the City of Pasadena, California; my business address is Anglin, Flewelling,
Rasmussen, Campbell & Trytten LLP, 199 S. Los Robles Avenue, Suite 600, Pasadena,
4 California 91101-2459.
5
6

A NGLIN F LEWELLING R ASMUSSEN C AMPBELL & T RYTTEN LLP

7

On the date below, I served a copy of the foregoing document entitled:
JOINT STIPULATION IN SUPPORT OF JOINT REQUEST TO EXTEND BRIEFING
DEADLINES RE: WELLS FARGO’S MOTION TO DISMISS PLAINTIFF’S
COMPLAINT

8 on the interested parties in said case as follows:
9
Served Electronically Via the Court’s CM/ECF System:
10
Counsel for Plaintiff:

11

Aldon L. Bolanos
Law Offices of Aldon L. Bolanos
Seven-Hundred “E” Street
Sacramento, California 95814
Tel: [phone]
Fax: [phone]

12
13
14
15
16

I declare under penalty of perjury under the laws of the United States of America that
the foregoing is true and correct. I declare that I am employed in the office of a member of the
17
Bar of this Court, at whose direction the service was made. This declaration is executed in
18 Pasadena, California on January 27, 2015.
19
20

Christine Daniel

/s/ Christine Daniel

(Type or Print Name)

(Signature of Declarant)

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93000/FR1513/01070185-3

CASE NO.: 4:15-CV-00048-JSW
CERTIFICATE OF SERVICE

Case4:15-cv-00048-JSW Document19-1 Filed01/27/15 Page1 of 2

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2
3
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8

UNITED STATES DISTRICT COURT

9

NORTHERN DISTRICT OF CALIFORNIA – OAKLAND DIVISION

10
CASE NO.: 4:15-CV-00048-JSW

11 Rosemary Greene,

13

[The Honorable Jeffrey S. White]

Plaintiff,

12
vs.

ORDER GRANTING STIPULATION TO
EXTEND BRIEFING DEADLINES RE:
WELLS FARGO’S MOTION TO DISMISS
PLAINTIFF’S COMPLAINT (DOC. NO.
12)

14 Wells Fargo Bank, N.A.,
15

Defendants.

16
17
18

The Court, having reviewed the Stipulation to extend the briefing deadlines relating to

19 Wells Fargo’s motion to dismiss plaintiff’s complaint (Document No. 12), and GOOD CAUSE
20 APPEARING, and PURSUANT TO STIPULATION, hereby Orders that:
21

The deadline for Plaintiff’s response to the motion to dismiss complaint is extended from

22 January 27, 2015 to February 6, 2015 and the deadline for Wells Fargo’s reply is extended to
23 February 13, 2015.
24
25 Dated: January 28, 2015
HONORABLE JEFFREY S. WHITE
UNITED STATES DISTRICT JUDGE

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28
93000/FR1513/01070232-2

1

CASE NO.: 4:15-CV-00048-JSW
ORDER GRANTING STIPULATION TO
EXTEND BRIEFING DEADLINES TO MTD

Case4:15-cv-00048-JSW Document19-1 Filed01/27/15 Page2 of 2

CERTIFICATE OF SERVICE

1

I, the undersigned, declare that I am over the age of 18 and am not a party to this action.
I am employed in the City of Pasadena, California; my business address is Anglin, Flewelling,
3 Rasmussen, Campbell & Trytten LLP, 199 S. Los Robles Avenue, Suite 600, Pasadena,
California 91101-2459.
4
2

5
6
7
8

On the date below, I served a copy of the foregoing document entitled:
ORDER GRANTING STIPULATION TO EXTEND BRIEFING DEADLINES RE:
WELLS FARGO’S MOTION TO DISMISS PLAINTIFF’S COMPLAINT
on the interested parties in said case as follows:

9

Served Electronically Via the Court’s CM/ECF System:

10

Aldon L. Bolanos
Law Offices of Aldon L. Bolanos
Seven-Hundred “E” Street
Sacramento, California 95814
Tel: [phone]
Fax: [phone]

11
12
13
14

I declare under penalty of perjury under the laws of the United States of America that
15 the foregoing is true and correct. I declare that I am employed in the office of a member of the
16 Bar of this Court, at whose direction the service was made. This declaration is executed in
Pasadena, California on January 27, 2015.
17
18
19

Christine Daniel
(Type or Print Name)

/s/ Christine Daniel
(Signature of Declarant)

20
21
22
23
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26
27
28
93000/FR1513/01070232-2

CASE NO.: 4:15-CV-00048-JSW
CERTIFICATE OF SERVICE