City of Richmond et al v. Royal Bank of Canada et al

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28 No. 3:25-cv-03348-CRB
No. 3:25-cv-03380-CRB
0 STIPULATION AND [PROPOSED]
ORDER RE CASE MANAGEMENT
DEADLINES
Matthew S. Melamed (SBN 260272)
Samuel Wilson (SBN 301086)
KELLER ROHRBACK L.L.P.
180 Grand Avenue, Suite 1380
Oakland, CA 94612
(510) 463-3900, Fax (510) 463-3901
mmelamed@kellerrohrback.com
Attorneys for Plaintiffs
Additional Counsel in Signature Block
UNITED STATES DISTRICT COURT
NORTHERN DISTRICT OF CALIFORNIA
CITY OF RICHMOND AND THE RICHMOND
JOINT POWERS FINANCING AUTHORITY,
Plaintiffs,
v.
ROYAL BANK OF CANADA, JP MORGAN
CHASE, PUBLIC RESOURCES ADVISORY
GROUP, AND THE MAJORS GROUP
Defendants.
No. 3:25-cv-03348-CRB
JOINT STIPULATION AND [PROPOSED]
ORDER REGARDING CASE
MANAGEMENT DEADLINES
CITY OF RICHMOND AND THE RICHMOND
JOINT POWERS FINANCING AUTHORITY,
EX REL. DAVID ALESHIRE, CITY
ATTORNEY FOR THE CITY OF RICHMOND,
CALIFORNIA
Plaintiffs,
v.
ROYAL BANK OF CANADA AND JPMORGAN
CHASE & CO.,
Defendants.
No. 3:25-cv-03380-CRB
Case 3:25-cv-03380-CRB Document 27 Filed 10/07/26 Page 1 of 8

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28 No. 3:25-cv-03348-CRB
No. 3:25-cv-03380-CRB
1 STIPULATION AND [PROPOSED]
ORDER RE CASE MANAGEMENT
DEADLINES
Pursuant to Federal Rule of Civil Procedure 6(b)(1) and Civil Local Rule 6-2, Plaintiffs City of
Richmond, Richmond Joint Powers Financing Authority, and the City Attorney for the City of
Richmond (collectively, “Plaintiffs”) and Defendants Royal Bank of Canada (“RBC”), JPMorgan
Chase & Co. (“JPMorgan”), and Public Resources Advisory Group (“PRAG”) (collectively,
“Defendants,”1 and, together with Plaintiffs, “the Parties”), by and through their counsel, hereby
stipulate as follows:
WHEREAS, on June 23, 2025, the Court entered the Parties’ Joint Stipulation to Extend
Current Case Deadlines (ECF No. 21) in Case No. 25-cv-03348 (the “Unjust Enrichment Action”);
WHEREAS, on August 12, 2025, the Court entered a stipulation staying the remaining case
deadlines established by ECF No. 21 because the City Attorney for the City of Richmond, the
prosecuting authority for Plaintiffs (“Plaintiffs’ Prosecuting Authority”), filed a California False
Claims Act case against RBC and JPMorgan (Case No. 25-cv-03380) based on allegations that
remained under seal (the “CA FCA Action”), and the parties to the Unjust Enrichment Action agreed
that, once the CA FCA Action was unsealed, they would seek relation of the two actions (ECF No.
27);
WHEREAS, on September 30, 2025, the parties to the Unjust Enrichment Action moved to
relate the CA FCA Action to the Unjust Enrichment Action (ECF No. 28), and on October 1, 2025, the
Court entered an order relating the CA FCA Action to the Unjust Enrichment Action (ECF No. 30);
WHEREAS, the Court entered a stipulated order in the Unjust Enrichment Action providing a
deadline of December 5, 2025 for Plaintiffs’ Prosecuting Authority to file an amended complaint in the
CA FCA Action and a deadline of 14 days after the amended CA FCA Action complaint is filed for the
1 Though named as a defendant in Case No. 25-cv-03348 (the “Unjust Enrichment Action”), the
Amended Complaint in that case (ECF No. 22) no longer asserts any claims against any JPMorgan
entity. Further, despite numerous attempts, Plaintiffs have not yet been able to effectuate service on
defendant The Majors Group. Plaintiff added JPMorgan Chase Bank, N.A. (“JPMC Bank”) as a
defendant in the CA FCA Action in the Second Amended Complaint (CA FCA Action ECF No. 20),
with each Defendant fully reserving all defenses to all claims asserted by Plaintiff in the Second
Amended Complaint, including, without limitation, all defenses that any such claim is time-barred
and that the addition of JPMC Bank does not relate back (Plaintiff disputes all such defenses and
reserves all rights with respect thereto). (See CA FCA Action ECF No. 18.)
Case 3:25-cv-03380-CRB Document 27 Filed 10/07/26 Page 2 of 8

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28 No. 3:25-cv-03348-CRB
No. 3:25-cv-03380-CRB
2 STIPULATION AND [PROPOSED]
ORDER RE CASE MANAGEMENT
DEADLINES
parties to jointly propose new case management deadlines to replace the deadlines in ECF No. 21 that
this Court stayed in ECF No. 27 (ECF No. 34);
WHEREAS, Plaintiffs’ Prosecuting Authority filed an amended complaint in the CA FCA
Action on December 5, 2025, the parties conferred regarding new case management deadlines and
coordination with the CA FCA action, and the parties in the Unjust Enrichment Action stipulated to
extend their time to propose new case management deadlines to December 23, 2025 (ECF No. 38);
WHEREAS, on December 23, 2025, the parties stipulated to extend the case management
deadlines into early 2026 (ECF No. 39);
WHEREAS, pursuant to stipulation, the Court reset the Parties’ deadline to file the Joint Case
Management Statement to February 13, 2026 and the date of the Case Management Conference to
February 20, 2026 (ECF No. 42);
WHEREAS, in February 2026, JPMorgan filed an action in the Southern District of New York
against the City of Richmond and the Richmond Joint Powers Financing Authority to enforce a release
agreement entered into by JPMorgan, and the City of Richmond and the Richmond Joint Powers
Financing Authority in 2015 (JPMorgan Chase & Co. v. City of Richmond and The Richmond Joint
Powers Financing Authority, No. 1:26-cv-1143 (S.D.N.Y. filed Feb. 10. 2026)) (the “S.D.N.Y.
Action”);
WHEREAS, the Parties filed their Joint Case Management Statement on February 13, 2026
(ECF No. 45);
WHEREAS, the Court sua sponte vacated the Initial Case Management Conference set for
February 20, 2026, and set new case management deadlines with the Parties’ Joint Case Management
Statement due on July 10, 2026 and the Initial Case Management Statement set for July 17, 2026 (ECF
No. 46);
WHEREAS, the City of Richmond and the Richmond Joint Powers Financing Authority filed a
motion to dismiss the S.D.N.Y. Action on May 11, 2026, JPMorgan opposed the motion on June 5,
2026, and the City of Richmond and the Richmond Joint Powers Financing Authority filed a reply on
June 15, 2026;
Case 3:25-cv-03380-CRB Document 27 Filed 10/07/26 Page 3 of 8

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28 No. 3:25-cv-03348-CRB
No. 3:25-cv-03380-CRB
3 STIPULATION AND [PROPOSED]
ORDER RE CASE MANAGEMENT
DEADLINES
WHEREAS, before the Initial Case Management Conference Set for July 17, 2026, all parties,
except for PRAG, agreed to stipulate to continue the Initial Case Management Conference for
approximately 90 days to provide time for the Court in the S.D.N.Y. Action to rule on the pending
Motion to Dismiss;
WHEREAS, the parties instead filed a Joint Case Management Statement on July 10, 2026,
wherein (i) PRAG asked the Court to allow it to proceed with filing a limited motion to dismiss,
(ii) Plaintiffs took the position that the Court should deny PRAG’s request and continue the Initial
Case Management Conference 90 days, or in the alternative that the Court move forward with all
motions to dismiss in both actions, (iii) RBC, JPMorgan and JPMC Bank did not object to PRAG’s
request but asked the Court not to proceed with their motions to dismiss until the S.D.N.Y. Action is
resolved, and (iv) RBC further asked that the Court consider whether the CA FCA Action and the
Unjust Enrichment Action should be consolidated after the S.D.N.Y. Action is resolved but before
proceeding with motions to dismiss in the actions in this Court;
WHEREAS, on July 15, 2026, the Court vacated the Initial Case Management Conference set
for July 17, 2026, and reset it for October 16, 2026 with the Joint Case Management Statement due
October 9, 2026;
WHEREAS, the Court in the S.D.N.Y. has not ruled on the pending motion to dismiss as of the
date of this filing;
WHEREAS, all parties agree that it would conserve the resources of the Court and the parties
to continue the Initial Case Management Conference for approximately 90 days to allow more time for
the Court in the S.D.N.Y. Action to rule on the pending Motion to Dismiss.
NOW, THEREFORE, THE PARTIES STIPULATE TO AND PROPOSE the following case
management deadlines:
 January 15, 2027: Deadline to file Joint Case Management Statement
 January 22, 2027: Initial Case Management Conference
Case 3:25-cv-03380-CRB Document 27 Filed 10/07/26 Page 4 of 8

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28 No. 3:25-cv-03348-CRB
No. 3:25-cv-03380-CRB
4 STIPULATION AND [PROPOSED]
ORDER RE CASE MANAGEMENT
DEADLINES
Submitted: October 6 2026.
KELLER ROHRBACK L.L.P.
By s/ Samuel Wilson
Matthew S. Melamed (SBN 260272)
Samuel Wilson (SBN 301086)
180 Grand Avenue, Suite 1380
Oakland, CA 94612
Telephone: (510) 463-3900
Facsimile: (510) 463-3901
Email: mmelamed@kellerrohrback.com
Email: swilson@kellerrohrback.com
Gary Gotto (admitted pro hac vice)
KELLER ROHRBACK L.L.P.
3101 North Central Avenue, Suite 1400
Phoenix, AZ 85012
Telephone: (602) 248-0088
Facsimile: (602) 248-2822
Email: ggotto@kellerrohrback.com
R. Bradley Miller (pro hac vice forthcoming)
R. BRADLEY MILLER LAW
301 North Alfred Street
Alexandria, VA 22314
Telephone: (919) 608-0795
Email: rbm@rbradleymillerlaw.com
Shannon L. Moore (SBN 243634)
Interim City Attorney
Kimberly Y. Chin (SBN 271333)
Senior Assistant City Attorney
CITY OF RICHMOND
CITY ATTORNEY’S OFFICE
450 Civic Center Plaza
Richmond, CA 94804-1630
Telephone: (510) 620-6509
Facsimile: (510) 620-6518
Email: daleshire@awaattorneys.com
Email: Shannon_Moore@ci.richmond.ca.us
Email: Kimberly_Chin@ci.richmond.ca.us
Attorneys for the City of Richmond and the Richmond
Joint Powers Financing Authority
STRADLING YOCCA CARLSON & RAUTH LLP
Case 3:25-cv-03380-CRB Document 27 Filed 10/07/26 Page 5 of 8

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28 No. 3:25-cv-03348-CRB
No. 3:25-cv-03380-CRB
5 STIPULATION AND [PROPOSED]
ORDER RE CASE MANAGEMENT
DEADLINES
By s/ Justin Owens
JUSTIN OWENS, State Bar No. 254733
jowens@stradlinglaw.com
JASON DE BRETTVILLE, State Bar No. 195069
jdebretteville@stradlinglaw.com
STRADLING YOCCA CARLSON & RAUTH
LLP
660 Newport Center Drive, Suite 1600
Newport Beach, CA 92660-6422
Telephone: 949 725 4000
Facsimile: 949 725 4100
Attorneys for Defendant Public Resources Advisory
Group
JONES DAY
By s/ Matthew Silveira
Matthew J. Silveira (SBN 264250)
(msilveira@jonesday.com)
JONES DAY
555 California St., 26th Floor
San Francisco, CA 94104
Telephone: (415) 875-5715
Jason Jurgens (pro hac vice forthcoming)
jjurgens@jonesday.com
Lauri W. Sawyer (pro hac vice forthcoming)
lsawyer@jonesday.com
JONES DAY
250 Vesey Street
New York, NY 10281
Telephone: (212) 326-3939
Facsimile: (212) 755-7306
Attorneys for Defendant Royal Bank of Canada
SULLIVAN & CROMWELL LLP
By s/ Robert Sacks__________
Robert A. Sacks (SBN 150146)
(sacksr@sullcrom.com)
Case 3:25-cv-03380-CRB Document 27 Filed 10/07/26 Page 6 of 8

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No. 3:25-cv-03380-CRB
6 STIPULATION AND [PROPOSED]
ORDER RE CASE MANAGEMENT
DEADLINES
Caleb J. Downs (SBN 346365)
(downsc@sullcrom.com)
1888 Century Park East
Los Angeles, CA 90067
Telephone: (310) 712-6600
Facsimile: (310) 712-8800
Paul H. Lazarow (SBN 311496)
(lazarowp@sullcrom.com)
SULLIVAN & CROMWELL LLP
550 Hamilton Avenue
Palo Alto, California 94301
Telephone: (650) 461-5600
Facsimile: (650) 461-5700
Attorneys for Defendants JPMorgan Chase & Co.
and JPMorgan Chase Bank, N.A.
(Defendants only in No. 3:25-cv-03380-CRB)
[PROPOSED] ORDER
PURSUANT TO STIPULATION, IT IS SO ORDERED
_______________________ ______________________________________________
Date The Honorable Charles R. Breyer, Senior District Judge
United States District Court for the Northern District of
California
October 7, 2026
Case 3:25-cv-03380-CRB Document 27 Filed 10/07/26 Page 7 of 8

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No. 3:25-cv-03380-CRB
7 STIPULATION AND [PROPOSED]
ORDER RE CASE MANAGEMENT
DEADLINES
SIGNATURE ATTESTATION
I, Samuel Wilson, attest pursuant to Northern District Civil Local Rule 5-1(h)(3) that all other
signatories to this document, on whose behalf this filing is submitted, concur in the filing’s content and
have authorized this filing. I declare under penalty of perjury that the foregoing is true and correct.
10/06/2026___ s/ Samuel Wilson
Date Samuel Wilson
Attorney for Plaintiffs
4926-2827-3872, v. 4
Case 3:25-cv-03380-CRB Document 27 Filed 10/07/26 Page 8 of 8