Pugh v. Bank of America,et al

Filing 10

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr. on 9/9/2013 ORDERING that the deadline for Defendant to respond to Plaintiff's Complaint is EXTENDED to 9/20/2013. (Zignago, K.)

1 BRYAN CAVE LLP
Andrea M. Hicks, California Bar No. 219836
2 Margaret K. Thies, California Bar No. 283408
Sharon L. Stewart, California Bar No. 235706
3 560 Mission Street, Floor 25
San Francisco, CA 94105
[phone]
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7 Attorneys for Defendant
BANK OF AMERICA, N.A.
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IN THE UNITED STATES DISTRICT COURT FOR THE

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Bryan Cave LLP
560 Mission Street, 25th Floor
San Francisco, CA 94105

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EASTERN DISTRICT OF CALIFORNIA

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JESSE N. PUGH
Plaintiff,
v.

BANK OF AMERICA, N.A., MORTGAGE
16 ELECTRONIC REGISTRATION
SYSTEMS, INC., SELECT PORTFOLIO
17 SERVICING, INC., NATIONAL
DEFAULT SERVICING CORPORATION
18 AND DEUTSCHE BANK NATIONAL
TRUST COMPANY AS TRUSTEE FOR
19 THE HARBOR VIEW MORTGAGE
LOAN TRUST SERIES 2005-7
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Defendants.
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Case No.: 2:13-CV-01635-MCE-KJN
AMENDED JOINT STIPULATION TO
CONTINUE DEFENDANT BANK OF
AMERICA, N.A.’S TIME TO
RESPOND TO PLAINTIFF’S
VERIFIED COMPLAINT

Complaint Filed: August 7, 2013
Trial Date:
Not Assigned

STIPULATION

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Defendant Bank of America, N.A., (“Defendant”) and Plaintiff Jesse N. Pugh (“Plaintiff”),

3 by and through their respective counsel of record hereby stipulate and agree as follows:
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1. Plaintiff filed his Complaint in this action on August 7, 2013.

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2. Defendant was served with the Complaint on or around August 14, 2013.

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3. There have been no previous time modifications entered in this case.

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4. Defense counsel was recently retained and requires additional time to investigate the

8 allegations from the Complaint.
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5. In order to allow time for defense counsel to investigate the facts of this case, allow

Bryan Cave LLP
560 Mission Street, 25th Floor
San Francisco, CA 94105

10 the parties to engage in good faith settlement negotiations, reduce the costs of litigation for all
11 parties, and unburden the Court’s docket, Plaintiff and Defendant agree and stipulate that
12 Defendant’s deadline to file a responsive pleading to Plaintiff’s Complaint shall be extended
13 until and including September 20, 2013.
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6.

This stipulated extension will not result in prejudice to any party and its impact on

15 judicial proceedings is not expected to be significant.
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This change will not alter the date of any event or any deadline already fixed by

17 Court order.
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IT IS SO STIPULATED.

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Dated: September 9, 2013

Respectfully submitted,
LAW OFFICES OF CHARLES T. MARSHALL

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By:

/s/ Charles T. Marshall
Charles T. Marshall
Attorneys for Plaintiff
JESSE N. PUGH

1 Dated: September 9, 2013

Respectfully submitted,

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BRYAN CAVE LLP

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Bryan Cave LLP
560 Mission Street, 25th Floor
San Francisco, CA 94105

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By:

/s/ Sharon L. Stewart
Sharon L. Stewart
Attorneys for Defendant

BANK OF AMERICA, N.A.

ORDER

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Having reviewed the stipulation of Plaintiff JESSE N. PUGH and Defendant BANK OF

3 AMERICA, N.A. and good cause appearing, the deadline for Defendant to respond to Plaintiff’s
4 Complaint is extended to September 20, 2013.
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IT IS SO ORDERED.

6 Dated: September 9, 2013
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Bryan Cave LLP
560 Mission Street, 25th Floor
San Francisco, CA 941105

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