Opinion
2:20-CV-00858-RFB-BNW
10-21-2022
MAURICIO JASSO, individually and in his capacity as the Court-Appointed Receiver of JAMA INVESTMENT GROUP, INC., et al., Plaintiffs, v. WELLS FARGO BANK, N.A., KATHERINE DARRALL, and JOSE RICO; Defendants.
SGRO & ROGER ANTHONY P. SGRO KELLY B. STOUT COLLEEN N. SAVAGE AND JEFFREY W. GUTCHESS COURTNEY CAPRIO JOANNA NIWOROWSKI AXS LAW GROUP, PLLC ATTORNEYS FOR PLAINTIFFS SNELL & WILMER JEFFREY WILLIS RICHARD S. GORDON ERICA J. STUTMAN HAYLEY J. CUMMINGS GREGORY J. MARSHALL JACOB C. JONES ATTORNEYS FOR DEFENDANT WELLS FARGO BANK, N.A.
SGRO & ROGER ANTHONY P. SGRO KELLY B. STOUT COLLEEN N. SAVAGE AND JEFFREY W. GUTCHESS COURTNEY CAPRIO JOANNA NIWOROWSKI AXS LAW GROUP, PLLC ATTORNEYS FOR PLAINTIFFS
SNELL & WILMER JEFFREY WILLIS RICHARD S. GORDON ERICA J. STUTMAN HAYLEY J. CUMMINGS GREGORY J. MARSHALL JACOB C. JONES ATTORNEYS FOR DEFENDANT WELLS FARGO BANK, N.A.
STIPULATION AND ORDER FOR EXTENSION TO FILE RESPONSE AND REPLY TO WELLS FARGO BANK, N.A.'S MOTION FOR PROTECTIVE ORDER REGARDING THE UNTIMELY AND IMPROPERLY NOTICED DEPOSITION OF ALEXANDER NELSON [ECF NO. 291]
(FIRST REQUEST)
Pursuant to Federal Rule of Civil Procedure 6(b)(1) and Local Rule IA 6-1, Plaintiffs Mauricio Jasso (“Jasso”), individually and in his capacity as the court-appointed receiver of JAMA Investment Group, Inc. (“JAMA”), Guillermo Sesma (“Sesma”), Sylvia Martinez Salinas (“Salinas”), Belisario Jasso Baldini (“Baldini”), Javier Ramirez Lares (“Lares”), Antonio Bachalani (“Bachalani”), Rodrigo Fernandez (“Fernandez”), Juan Romero (“Romero”), and Bernardo Villacecias (“Villacecias”) (collectively, “Plaintiffs”), and Defendants Wells Fargo Bank, N.A. (“Wells Fargo”), Katherine Darrall (“Darrall”), (collectively, “Defendants” and together with Plaintiffs, the “Parties”), hereby stipulate and agree to extend Plaintiffs' deadline to file their Response to Wells Fargo Bank, N.A.'s Motion for Protection Regarding the Untimely and Improperly Noticed Deposition of Alexander Nelson [ECF No. 291] from October 21, 2022 to October 27, 2022 and extend Wells Fargo Bank, N.A.'s deadline to file its respective Reply by 5 days (from November 3 to November 8, 2022) for the following reasons:
1. On October 7, 2022, Wells Fargo Bank, N.A. filed a Motion for Protection Regarding the Untimely and Improperly Noticed Deposition of Alexander Nelson [ECF No. 291].
2. Accordingly, Plaintiffs' Response to the Motion for Protection is due on October 21, 2022.
3. Counsel for Plaintiffs has been working diligently on their Plaintiffs' Response to the Motion for Protection but requires additional time due to multiple deadlines falling within this fourteen-day period, including the deposition schedule in this case, and scheduling deadlines in other cases.
4. No prejudice will result due to a 1-week extension, as the hearing on this motion has been scheduled for November 16, 2022.
5. If the extension is granted, Wells Fargo's reply in support of its motion would be due November 3, 2022. Wells Fargo seeks a few extra days until November 8, 2022 due to scheduling deadlines in this and other cases. This would result in briefing on this motion completed more than one week before the November 16 hearing date.
6. This extension request is sought in good faith and is not made for the purpose of delay.
THEREFORE, for good cause shown, the Parties respectfully request an extension of deadlines as follows:
• October 27, 2022 - Deadline for Plaintiffs to file their Response to Wells Fargo Bank, N.A.'s Motion for Protection Regarding the Untimely and Improperly Noticed Deposition of Alexander Nelson [ECF No. 291]
• November 8, 2022 - Deadline for Wells Fargo to file its Reply in Support of the motion.
IT IS SO ORDERED.