STATEMENT OF POSITION re: pldg. ( 1 in MDL 2954) Filed by Plaintiff Guofeng Ma… — Agent Fee Litigation (Dkt. 41)

Summary

A stipulation of DNM Contracting, Inc., filed before the United States Judicial Panel on Multidistrict Litigation in In re Wells Fargo Paycheck Protection Plan Litigation, MDL Docket No: 2954, and dated June 30, 2020. The filing identifies DNM Contracting, Inc. as the movant in a motion to transfer actions to the Southern District of Texas for coordinated or consolidated pretrial proceedings. It stipulates that the case of Ma v. Wells Fargo & Co., et al., 3:20-cv-03697 (N.D. Cal.) should be removed from the Schedules of Actions filed in the matter. It states that the parties agree that this action involves questions of fact and legal theories distinct from those at issue in the other included actions. The document is signed by counsel of record for the plaintiff.

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                                    BEFORE THE
                          UNITED STATES JUDICIAL PANEL ON
                             MULTIDISTRICT LITIGATION

  IN RE WELLS FARGO PAYCHECK                      §
  PROTECTION PLAN LITIGATION                      §
                                                  §
                                                  §     MDL DOCKET NO: 2954
                                                  §



                  STIPULATION OF DNM CONTRACTING, INC.


       Plaintiff DNM Contracting, Inc., Movant in Plaintiff’s Motion for the Transfer of Actions

to the Southern District of Texas Pursuant to 28 U.S.C. § for Coordinated or Consolidated Pretrial

Proceedings, through its counsel of record, stipulates that the case of Ma v. Wells Fargo & Co., et

al., 3:20-cv-03697 (N.D. Cal.) should be removed from the Schedules of Actions filed in this

matter. The parties agree that this action involves questions of fact and legal theories that are

distinct from those at issue in the other included actions.

                                               Respectfully submitted,

Dated: June 30, 2020                           /s/ Alfonso Kennard, Jr.
                                               Alfonso Kennard, Jr.
                                               KENNARD LAW PC
                                               2603 Augusta Drive, Suite 1450
                                               Houston Texas 77057
                                               Telephone: (713) 742-0900
                                               Facsimile: (713) 742-0951
                                               Email: alfonso.kennard@kennardlaw.com

                                               Attorneys for Plaintiff DNM Contracting, Inc.


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