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Ally Bank, Wesley W. Halihan and Gina Halihan v. Wells Fargo Bank

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA


August 8, 2011

ALLY BANK, WESLEY W. HALIHAN AND GINA HALIHAN, PLAINTIFFS,
v.
WELLS FARGO BANK, N.A., AND
DOES 1 THROUGH 10,
DEFENDANTS.

The opinion of the court was delivered by: Samuel Conti Judge of the United States District Court

STEPHEN C. SETO, SBN 175458 (sseto@sbllp.com) SHAPIRO BUCHMAN PROVINE BROTHERS SMITH LLP 1333 N. California Blvd., Suite 350 Walnut Creek, CA 94596 Telephone: (925) 944-9700 Facsimile: (925) 944-9701 Attorneys for Plaintiffs ALLY BANK, WESLEY W. HALIHAN and GINA HALIHAN

STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE FIRST AMENDED COMPLAINT STIPULATION

IT IS HEREBY STIPULATED by and between the parties hereto, through their respective 21 counsel, that this court may allow Plaintiffs ALLY BANK, WESLEY W. HALIHAN, and GINA 22 HALIHAN ("Plaintiffs") to file a first amended complaint, a copy of which is attached hereto as 23 Exhibit "A", adding new plaintiffs, adding additional persons and entities as defendants and 24 adding causes of action against the newly named defendants pursuant to information obtained by 25 plaintiffs evidencing that the newly named defendants engaged in a common scheme to defraud 26 numerous sellers and buyers of real property and some of their agents and lenders out of over one PROVINE BROTHERS SMITH LLP LEAVE TO FILE FIRST AMENDED COMPLAINT SHAPIRO BUCHMAN 243808.1 million seven hundred thousand dollars ($1,700,000) through phantom sales, sham loans and the 2 execution of fraudulent reconveyances of deeds of trust. 3

ORDER

PURSUANT TO THE FOREGOING STIPULATION, IT IS SO ORDERED that

Plaintiffs ALLY BANK, WESLEY W. HALIHAN, and GINA HALIHAN ("Plaintiffs") are 19 hereby allowed to file the within proposed first amended complaint. 20

Dated: August ___, 2011 T

T T N IT IS SO ORDERED

N Samuel Conti R

Judge SHAPIRO BUCHMAN

20110808

© 1992-2011 VersusLaw Inc.



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