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

Filing 163

ORDER granting 162 Stipulation Re: 160 Motion. Responses due by 8/9/2021. Replies due by 8/23/2021. Signed by Judge James C. Mahan on 7/16/2021. (Copies have been distributed pursuant to the NEF - DRS)

Case 2:17-cv-01514-JCM-NJK Document 162 Filed 07/15/21 Page 1 of 4

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Amy F. Sorenson, Esq.
Nevada Bar No. 12495
Kelly H. Dove, Esq.
Nevada Bar No. 10569
Blakeley E. Griffith, Esq.
Nevada Bar No. 12386
SNELL & WILMER L.L.P.
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, NV 89169
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Attorneys for 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

Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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EDYTA GRYGLAK, formerly known as
EDYTA A. FROMKIN,

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

Plaintiff,
vs.
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,

STIPULATION AND ORDER TO
EXTEND BRIEFING SCHEDULE ON
PLAINTIFF’S RULE 37(c) MOTION
[ECF No. 160]
(FIRST REQUEST)

Defendants.

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Defendants HSBC Bank USA, N.A., as trustee for Wells Fargo Home Equity Asset-Backed

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Certificates, Series 2006-3, by its Attorney-in-fact Wells Fargo Bank, N.A.; Wells Fargo Bank,

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N.A.; and Wells Fargo Asset Securities Corporation (collectively, “Wells Fargo”), and Plaintiff

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Edyta Gryglak (“Plaintiff” and together with Wells Fargo, the “Parties”) hereby file the following

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stipulation to extend the briefing schedule for Plaintiff’s “Rule 37(c) Motion to Confirm That Her

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Inadvertent Failure to File a Rule 26(A) Initial Disclosure Was Harmless” (“Rule 37(c) Motion”)

Case 2:17-cv-01514-JCM-NJK Document 162 Filed 07/15/21 Page 2 of 4

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(ECF No. 160), to synchronize it with the summary judgment briefing schedule that this Court has

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approved (ECF No. 155):

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1.

On May 28, 2021, Wells Fargo filed its Renewed Summary Judgment Motion (ECF

No. 151), pursuant to a May 24, 2021 stipulation and order (ECF 150).

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2.

Pursuant to the July 6, 2021 stipulation granted by this Court, an extended, unified

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briefing schedule was created for both the Renewed Summary Judgment Motion and Plaintiff’s

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own summary judgment motion on the issue of damages (the “Gryglak Summary Judgment

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Motion”) (ECF No. 154):

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a.

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Judgment Motion and her response to Wells Fargo’s Renewed Summary Judgment Motion

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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Snell & Wilmer

July 8, 2021: the deadline for Plaintiff to file the Gryglak Summary

b.

August 9, 2021: the deadline for Wells Fargo’s response to the Gryglak

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Summary Judgment Motion and its reply in further support of its Renewed Summary

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Judgment Motion

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c.

August 23, 2021: the deadline for Plaintiff’s reply in further support of the

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Gryglak Summary Judgment Motion

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3.

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Plaintiff timely filed her response to Wells Fargo’s Renewed Summary Judgment

Motion (ECF No. 156) and the Gryglak Summary Judgment Motion (ECF No. 159).

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4.

Along with these briefs, Plaintiff contemporaneously filed the Rule 37(c) Motion

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(ECF No. 160), which exclusively addresses issues raised in Wells Fargo’s Renewed Summary

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Judgment Motion and the Gryglak Summary Judgment Motion.

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5.

A response to the Rule 37(c) Motion is currently due on July 23, 2021.

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6.

The Parties therefore agree that it would be efficient to synchronize the briefing

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schedule for the Rule 37(c) Motion with the schedule for the summary judgment motions.

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Case 2:17-cv-01514-JCM-NJK Document 162 Filed 07/15/21 Page 3 of 4

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7.

The Parties THEREFORE STIPULATE that the deadline for Wells Fargo’s

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response to the Rule 37(c) Motion (ECF No. 160) is extended to August 9, 2021, and the deadline

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for Plaintiff’s reply in support of that motion is extended to August 23, 2021.

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Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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Dated: July 15, 2021

Dated: July 15, 2021

SNELL & WILMER L.L.P.

THE GRIFFITH FIRM

By: /s/ Kelly H. Dove
Amy F. Sorenson, Esq.
Kelly H. Dove, Esq.
Blakeley E. Griffith, Esq.

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

Attorneys for Defendants

Attorney for Plaintiff

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ORDER

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Good cause appearing, IT IS HEREBY ORDERED that the deadline for Wells Fargo’s

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response to the Rule 37(c) Motion (ECF No. 160) is extended to August 9, 2021, and the deadline

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for Plaintiff’s reply in support of that motion is extended to August 23, 2021.

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IT IS SO ORDERED.

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July 16, 2021
DATED _______________________

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___________________________
U.S. DISTRICT COURT JUDGE

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Case 2:17-cv-01514-JCM-NJK Document 162 Filed 07/15/21 Page 4 of 4

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CERTIFICATE OF SERVICE

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I hereby certify that on July 15, 2021, I electronically filed the foregoing STIPULATION

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AND ORDER TO EXTEND BRIEFING SCHEDULE ON PLAINTIFF’S RULE 37(c)

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MOTION [ECF No. 160] with the Clerk of Court for the U.S. District Court, District of Nevada

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

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will be served by the CM/ECF system.

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DATED this 15th day of July 2021.

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/s/ Maricris Williams
An Employee of Snell & Wilmer L.L.P.

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Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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4828-4677-9122

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