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Gregory R. Raifman and Susan Raifman, Husband and Wife, Individually and v. Wachovia Securities

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA - OAKLAND DIVISION


May 7, 2013

GREGORY R. RAIFMAN AND SUSAN RAIFMAN, HUSBAND AND WIFE, INDIVIDUALLY AND ON BEHALF OF THEIR MARITAL COMMUNITY AND ASTRUSTEES OF THE RAIFMAN FAMILY REVOCABLE INTERVIVOS TRUST AND AS BENEFICIARIES OF THE PALLADIAN TRUST;
GEKKO HOLDINGS, LLC;
EDWARD AND LORRAINE KURATA, AS HUSBAND AND WIFE; JAMES LOOMIS;
JEFFREY CHOU; AND
BRUCE CARDINAL, AS TRUSTEE OF THE ROBERT J. CARDINAL
GRANDCHILDREN'S TRUST, AND
THE MARION I. CARDINAL TRUST, AND AS MANAGING MEMBER OF REDBIRD INVESTMENT GROUP, LLC
PLAINTIFFS,
v.
WACHOVIA SECURITIES, LLC, N/K/A WELLS FARGO ADVISORS, LLC, DEFENDANT.

The opinion of the court was delivered by: Hon. Saundra J. Armstrong United States District Judge

STIPULATION TO EXCEED MOTION PAGE LIMIT Action Filed: April 1, 2011 [Removed from California State Court] Hon. Saundra B. Armstrong

STIPULATION TO EXCEED MOTION PAGE LIMIT

Whereas, on May 2, 2013, Plaintiffs Gregory R. Raifman and Susan Raifman, husband and 2 wife, individually and on behalf of their marital community and as Trustees of The Raifman Family 3 Revocable Inter Vivos Trust, as beneficiaries of The Palladian Trust, and as sole members of Gekko 4 Holdings, LLC; Edward and Lorraine Kurata, husband and wife; James Loomis; Jeffrey Chou; and 5 Bruce Cardinal, as Trustee of the Robert J. Cardinal Grandchildren's Trust, and as Trustee of the 6 Marion I. Cardinal Trust, and as Managing Member of Redbird Investment Group, LLC 7 (collectively, "Plaintiffs"), filed their Third Amended Complaint ("TAC") in this action, pursuant to 8 an agreement between the parties and the Order of this Court; 9

Whereas the parties met and conferred but were unable to reach a resolution on a number of the issues discussed regarding allegations made in the TAC; Whereas counsel for Defendant Wachovia Securities, LLC ("Defendant") informed Plaintiffs' counsel that Defendant intends to file a Motion to Dismiss the TAC; and 13 Whereas Defendant believes it needs more than the 15 pages permitted by the Court's Standing Order to fully and properly address all issues raised in Plaintiffs' TAC; 15 NOW, THEREFORE, the parties, through their counsel, hereby stipulate and agree, pursuant to Local Rule 7-11(a), that Defendant may exceed the 15 page limit on its Motion by five pages, and 17 file a Motion to Dismiss not to exceed 20 pages.

DATED: May 6, 2013 DAVID A. PICON RONALD E. WOOD JENNIFER L. ROCHE PROSKAUER ROSE LLP 19 20 21 /s/ Ronald E. Wood Ronald E. Wood 22 23 Attorneys for Defendant DATED: May 6, 2013 TOD ARONOVITZ 24 BARBARA PEREZ ANDREW ZELMANOWITZ 25 26 /s/ Tod Aronovitz 27 TOD ARONOVITZ Attorney for Plaintiffs

PURSUANT TO STIPULATION, IT IS SO ORDERED.

20130507

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