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

Filing 53

ORDER Granting 52 Third Stipulation for Extension of Time Re: 45 Motion for Summary Judgment. Responses due by 11/8/2018. Replies due by 11/29/2018. Signed by Judge James C. Mahan on 10/25/2018. (Copies have been distributed pursuant to the NEF - SLD)

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

THIRD STIPULATION AND ORDER
EXTENDING SUMMARY JUDGMENT
BRIEFING SCHEDULE

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

Defendants.

16
17
18
19
20
21

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”) and Plaintiff
Edyta Gryglak (“Plaintiff” and together with Defendants, the “Parties”) hereby stipulate to extend
the briefing schedule on Defendants’ Motion for Summary Judgment [ECF 45] as follows:

22

(i)

the due date for Plaintiff’s opposition papers shall be extended by tw
weeks, from October 25, 2018, to November 8, 2018; and

(ii)

Defendants’ time to file reply papers be three weeks later, on
November 29, 2018.

23

24
25
26
27

(Third Request)

WHEREAS Defendants filed their Motion for Summary Judgment on September 13, 2018;
WHEREAS the Court previously granted the parties’ First Stipulation and Order, which
extended Plaintiff’s due date to file opposition papers by two weeks, from October 4, 2018 to

28
-14820-2175-1115
21894686.2

1

October 18, 2018, and the parties’ Second Stipulation and Order, which extended Plaintiff’s due

2

date by one week, from October 18, 2018 to October 25, 2018, and extended Defendants’ response

3

time from two weeks to three weeks;

4
5

WHEREAS the first and second extensions were necessary due to the hospitalization of
Plaintiff’s counsel and his intense work schedule upon returning to work;
WHEREAS Plaintiff counsel’s work scheduled has continued to prevent him from

7

completing Plaintiff’s opposition papers, including a statutory deadline to file a Rule 52 motion to

8

alter or amend a bankruptcy court judgment on October 19, 2018, a court-ordered deadline to file

9

a motion for fees and costs on October 22, 2018, complex discovery deadlines on October 22, 2018

10

and October 23, 2018 in cases pending, respectively, in the Central District of California and the

11

District of Colorado, summary judgment opposition due on October 24, 2018 in a case in the

12

Eastern District of Michigan (for which an extension is being sought), an October 31, 2018 trial in

13

New York state court with pre-trial lists and motions due on October 26, 2018; and motion hearings

14

in a case in Florida state court on October 29 and November 1, 2018;

6

15

WHEREAS Plaintiff’s counsel needs an additional two weeks to complete and file

16

Plaintiffs’ opposition papers, which would extend the due date for opposition papers to November

17

8, 2018;

18

THE PARTIES HEREBY STIPULATE:

19

1.

20

The briefing schedule on Defendants’ motion for summary judgment is extended as

follows:

21

(i)

Opposition papers are due on November 8, 2018;

22

(ii)

Reply papers are due on November 29, 2018.

Dated: October 24, 2018

Dated: October 24, 2018

24

23

SNELL & WILMER L.L.P.

THE GRIFFITH FIRM

25

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

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

26
27
28

-24820-2175-1115
21894686.2

1

ORDER

2
3
4

IT IS HEREBY ORDERED that the briefing schedule on Defendants’ motion for
summary judgment is extended as follows:
(i)

6
7
8

Opposition papers are due on November 8, 2018;

(ii)

5

Reply papers are due on November 29, 2018..

IT IS SO ORDERED.
DATED this 25th day of October 2018.
___

9

____________________________
U.S. DISTRICT COURT JUDGE

10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
-34820-2175-1115
21894686.2

1

CERTIFICATE OF SERVICE

2

I hereby certify that on October 24, 2018, I electronically filed the foregoing with the Clerk

3

of Court for the U.S. District Court, District of Nevada by using the Court’s CM/ECF system.

4

Participants in the case who are registered CM/ECF users will be served by the CM/ECF system.

5
6

DATED this 24th day of October 2018.
/s/ Edward Griffith

7

EDWARD GRIFFITH, ESQ

8
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