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

Filing 142

ORDER granting 141 Stipulation to Extend deadlines to 136 Motion to Reopen Dispositive Motions Deadline; Responses due by 4/14/2021. Replies due by 4/28/2021. Signed by Judge James C. Mahan on 4/2/2021. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:17-cv-01514-JCM-NJK Document 141 Filed 03/31/21 Page 1 of 4

1
2
3
4
5

Edward Griffith
(admitted pro hac vice)
THE GRIFFITH FIRM
45 Broadway, Suite 2200
New York, New York 10006
[phone]
[phone] (cell)
[e-mail]
Attorneys for Plainitff Edyta Gryglak

6

UNITED STATES DISTRICT COURT

7

DISTRICT OF NEVADA

8
9

EDYTA GRYGLAK, formerly known as
EDYTA A. FROMKIN,

Case No.: 2:17-cv-01514-JCM-NJK

Plaintiff,

10
11

vs.

12

HSBC BANK USA, N.A., as trustee for
WELLS FARGO HOME EQUITY ASSETBACKED 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,

13

14
15

18
19
20
21
22
23

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, “Defendants” or “Wells Fargo”)
and Plaintiff Edyta Gryglak (“Plaintiff” and together with Defendants, the “Parties”) hereby
stipulate to extend by the current briefing schedule for Defendants’ Motion to Reopen Dispositive
Motion Deadline [ECF 136] (the “Motion to Reopen”) to allow Plaintiff two additional weeks to
prepare and file her response and to adjust the due date for Defendants’ reply to avoid defense
counsel’s conflicts in other matters. If approved, this stipulation would extend the due date for

24

(THIRD REQUEST)

Defendants.

16
17

STIPULATION AND ORDER
TO EXTEND PLAINTIFF’S TIME
TO RESPOND TO DEFENDANTS’
MOTION TO REOPEN DISPOSITIVE
MOTION DEADLINE

25
26
27

Plaintiff’s opposition from March 31, 2021 to April 14, 2021, and the due date for Defendants’
reply from April 14, 2021 to April 28, 2021.
WHEREAS Defendants filed their Motion to Reopen on February 24, 2021;

28
-14820-2175-1115
21894686.2

Case 2:17-cv-01514-JCM-NJK Document 141 Filed 03/31/21 Page 2 of 4

1

WHEREAS the Court granted Plaintiff Edyta Gryglak’s two prior requests to extend the

2

due date to file opposing papers by one week from March 10, 2021 to March 31, 2021, see Orders

3

[ECF 138 and 140];

4

WHEREAS Ms. Gryglak’s lead counsel, Edward Griffith, needs an additional two weeks

5

to prepare and file Plaintiff’s opposition due to his litigation schedule on other matters, moderate

6

side effects he experienced after his second Moderna COVID-19 vaccination and to continue his

7

analysis of certain potentially relevant information; and

8

WHEREAS Wells Fargo consents to this request;

9

THE PARTIES HEREBY STIPULATE:

10

1.

Ms. Gryglak’s due date to file papers in opposition to Wells Fargo’s Motion to

11

Reopen is extended by two weeks, from March 31, 2021 to April 14, 2021 and the due date for

12

Wells Fargo’s reply papers is extended from April 14, 2021 to April 28, 2021.
Dated: March 31, 2021

Dated: March 31, 2021

14

SNELL & WILMER L.L.P.

THE GRIFFITH FIRM

13

15
16
17
18
19
20

/s/ Edward Griffith

/s/ Blakeley E. Griffith
By:
Blakeley E. Griffith (NV Bar No. 12386)
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
[phone]

[phone] (fax)

By:
Edward Griffith (pro hac vice)
45 Broadway, Suite 2200
New York, New York 10006
[phone] (mobile)
[phone] (fax)

Attorneys for Defendants

Attorney for Plaintiff

21
22
23

24
25
26
27
28
-24820-2175-1115
21894686.2

Case 2:17-cv-01514-JCM-NJK Document 141 Filed 03/31/21 Page 3 of 4

ORDER

1
2

IT IS HEREBY ORDERED that the due date for Plaintiff to file papers in opposition to

3

Defendants’ Motion to Reopen Dispositive Motion Deadline is extended by two weeks, from

4

March 31, 2021 to April 14, 2021, and the due date for Defendants to file reply papers is extended

5

from April 14, 2021 to April 28, 2021.

6

IT IS SO ORDERED.

7

April 2, 2021.
DATED this ___ day of April 2021

8
____________________________
U.S. DISTRICT COURT JUDGE

9
10
11
12
13

14
15
16
17
18
19
20
21
22
23

24
25
26
27
28
-34820-2175-1115
21894686.2

Case 2:17-cv-01514-JCM-NJK Document 141 Filed 03/31/21 Page 4 of 4

CERTIFICATE OF SERVICE

1
2

I hereby certify that on March 31, 2021, I electronically filed the foregoing

3

STIPULATION with the Clerk of Court for the U.S. District Court, District of Nevada by using

4

the Court’s CM/ECF system. Participants in the case who are registered CM/ECF users will be

5

served by the CM/ECF system.

6
7

DATED this 31st day of March 2021.
/s/ Edward Griffith

8

EDWARD GRIFFITH, ESQ

9
10
11
12
13

14
15
16
17
18
19
20
21
22
23

24
25
26
27
28
-44820-2175-1115
21894686.2