Gryglak v. HSBC Bank USA, N.A., et al

Filing 13

ORDER Granting 12 Stipulation for Extension of Time (First Request) re 10 MOTION to Dismiss. Plaintiff's Responses due by 9/11/2017. Signed by Judge James C. Mahan on 8/30/2017. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-01514-JCM-NJK Document 12 Filed 08/29/17 Page 1 of 2

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AVRAMSKI LAW, PC
Boris Avramski, Esq.
Nevada Bar No. 11350
602 South 10th Street
Las Vegas, NV 89101
Phone: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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EDYTA GRYGLAK, formerly known
as EDYTA A. FROMKIN,

)
)
)
Plaintiff,
)
vs.
)
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HSBC BANK USA, N.A., as trustee for
)
WELLS FARGO HOME EQUITY ASSET- )
BACKED CERTIFICATES, Series 2006-3, by )
its Attorney-in-fact WELLS FARGO BANK, )
N.A., WELLS FARGO BANK, N.A., and
)
WELLS FARGO ASSET SECURITIES
)
CORPORATION,
)
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Defendants.
)
)

Case No.: 2:17-cv-01514-JCM-NJK
STIPULATION AND ORDER
EXTENDING PLAINTIFF’S DUE
DATE TO RESPOND TO MOTION
TO DISMISS
FIRST REQUEST
Motion Filed August 14, 2017

Plaintiff Edyta Gryglak and Defendants HSBC Bank USA, N.A., as trustee for Wells
Fargo Home Equity Asset-Backed Certificates, Series 2006-3, by its Attorney-in-fact Wells
Fargo Bank, N.A., Wells Fargo Bank, N.A. and Wells Fargo Asset Securities Corporation
(collectively, “Wells Fargo”) agree as follows:
WHEREAS on August 14, 2017, Wells Fargo filed a motion to dismiss the second, third,
fourth, and fifth causes of action of the Complaint (Doc. No. 10) (the “Motion”);
WHEREAS the due date for plaintiff Edyta Gryglak to respond to the Motion was
Monday August 28, 2017;
WHEREAS this is Ms. Gryglak’s first request for an extension of time, which is
necessary due to the vacation and work schedules of her counsel;
WHEREAS Wells Fargo consents to this extension, which is not intended to cause any
delay or prejudice to any party;

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Case 2:17-cv-01514-JCM-NJK Document 12 Filed 08/29/17 Page 2 of 2

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WHEREAS Ms. Gryglak is filing this stipulation and proposed order one day late, on

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August 29, 2017 rather than August 28, 2017, due to excusable neglect on the part of her

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counsel;1

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IT IS HEREBY STIPULATED AS FOLLOWS:

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1.

The due date for Ms. Gryglak’s response to the Motion is extended by two weeks,

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from August 28, 2017 to September 11, 2017.

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Dated this 29th day of August 2017.

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AVRAMSKI LAW, PC
Counsel for Plaintiff

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/s/ Boris Avramski

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SNELL & WILMER L.L.P.
Counsel for Defendants
/s/ Blakeley E. Griffith
__________________________
Blakeley E. Griffith, Esq.
Nevada Bar No. 12386
SNELL & WILMER L.L.P.
3883 Howard Hughes Parkway
Las Vegas, NV 89169
Phone: [phone]
Fax: [phone]
[e-mail]

Boris Avramski, Esq.
Nevada Bar No. 11350
AVRAMSKI LAW, PC
4640 W. Charleston Blvd.
Las Vegas, NV 89102
Phone: [phone]
Fax: [phone]
[e-mail]

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IT IS SO ORDERED:

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____________________________________________
UNITED STATES DISTRICT JUDGE

August 30, 2017
DATED: ___________________________

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In particular, on August 28, 2017, Ms. Gryglak’s lead counsel, Edward Griffith, had just
returned from a vacation and was traveling in Florida for a court hearing in another case; this
stipulation and proposed order was not prepared and filed until the following day due to a
misunderstanding between Mr. Griffith and his staff.
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