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

Filing 82

ORDER Granting 81 Second Stipulation for Extension of Time Re: 74 Motion for Preliminary Injunction. Replies due by 4/29/2019. Signed by Judge James C. Mahan on 4/26/2019. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:17-cv-01514-JCM-NJK Document 81 Filed 04/25/19 Page 1 of 4

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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

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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,

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

Plaintiff,

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vs.

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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,

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(Second Request)

Defendants.

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STIPULATION AND ORDER
EXTENDING PLAINTIFF’S
DUE DATE TO FILE REPLY IN
SUPPORT OF MOTION FOR
PRELIMINARY INJUNCTION

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
by two business days the due date for Plaintiff to file her Reply in further support of her Motion for
Preliminary Injunction [ECF 74]. If approved, this stipulation would extend the due date from
Thursday, April 25, 2019 to Monday, April 29, 2019.
WHEREAS the current deadline for Plaintiff to file her Reply in further support of her
Motion for Preliminary Injunction is April 25, 2019.
WHEREAS the Parties now stipulate and agree to extend the time for Plaintiff to file her
Reply from April 25, 2019 to April 29, 2019.

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Case 2:17-cv-01514-JCM-NJK Document 81 Filed 04/25/19 Page 2 of 4

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WHEREAS, this is the second request for an extension of time for Plaintiff to file her Reply

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in further support of her Motion for Preliminary Injunction and is not intended to cause any delay

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or prejudice to any party. The reason for the extension is the workload of Plaintiff’s counsel over

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the last week, including commencing a lawsuit in the Superior Court of California, County of Los

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Angeles, which had to be filed on Friday, April 19, 2019 to avoid statute of limitations issues,

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papers in opposition to a motion to dismiss that were due on Tuesday, April 22, 2019 in an action

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pending in the United States District Court for the Eastern District of Michigan, and filing the

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opening brief and appendix due on Wednesday, April 23, 2019 in a bankruptcy appeal pending in

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the United States District Court for the Southern District of Florida. This intense work schedule has

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caused him to need more time to prepare and file Plaintiff’s Reply.

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THE PARTIES HEREBY STIPULATE:

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The deadline for Plaintiff to file her Reply in further support of her Motion for

Preliminary Injunction is extended from Thursday April 25, 2019 to Monday April 29, 2019.
Dated: April 25, 2019

Dated: April 25, 2019

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SNELL & WILMER L.L.P.

THE GRIFFITH FIRM

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/s/ Blakeley E. Griffith

/s/ Edward 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]
[phone] (fax)

Attorneys for Defendants

Attorney for Plaintiff

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Case 2:17-cv-01514-JCM-NJK Document 81 Filed 04/25/19 Page 3 of 4

ORDER

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

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support of her Motion for Preliminary Injunction is extended by two business days, from

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Thursday April 25, 2019 to Monday April 29, 2019.

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IT IS SO ORDERED.

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April 26, 2019.
DATED this ___ day of April 2019.

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____________________________
U.S. DISTRICT COURT JUDGE

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Case 2:17-cv-01514-JCM-NJK Document 81 Filed 04/25/19 Page 4 of 4

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CERTIFICATE OF SERVICE

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I hereby certify that on April 25, 2019, I electronically filed the foregoing STIPULATION

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

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

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system.

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DATED this 25th day of April 2019.
/s/ Edward Griffith

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EDWARD GRIFFITH, ESQ

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