Pugh v. Bank of America,et al

Filing 14

STIPULATION and ORDER signed by Chief Judge Morrison C. England, Jr on 9/26/13: The deadline for Defendant to respond to Plaintiff's Complaint is extended to October 2, 2013. (Kaminski, H)

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]
4 Telephone:
Facsimile:
[phone]
[e-mail]
5 Email:
[e-mail]
[e-mail]
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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 941105

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EASTERN DISTRICT OF CALIFORNIA

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JESSE N. PUGH
Plaintiff,

Hon. Morrison C. England, Jr.

v.

JOINT STIPULATION TO FURTHER
CONTINUE DEFENDANT BANK OF
AMERICA, N.A.’S TIME TO
RESPOND TO PLAINTIFF’S
VERIFIED COMPLAINT

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

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. Plaintiff and Defendant previously stipulated to one extension of time for Defendant

6 to respond to the Complaint until September 20, 2013.
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3. In order to allow time for the parties to engage in good faith settlement negotiations,

8 including a possible loan modification review, reduce the costs of litigation for all parties, and
9 unburden the Court’s docket, Plaintiff and Defendant agree and stipulate that Defendant’s

Bryan Cave LLP
560 Mission Street, 25th Floor
San Francisco, CA 941105

10 deadline to file a responsive pleading to Plaintiff’s Complaint shall be extended until and
11 including October 2, 2013.
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4.

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

13 judicial proceedings is not expected to be significant.
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5.

This change will not alter the date of any event or any deadline already fixed by

15 Court order.
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IT IS SO STIPULATED.

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Dated: September 26, 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 26, 2013

Respectfully submitted,

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BRYAN CAVE LLP

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By:

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BANK OF AMERICA, N.A.

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ORDER

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

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

9 AMERICA, N.A., and good cause appearing, the deadline for Defendant to respond to Plaintiff’s

Bryan Cave LLP
560 Mission Street, 25th Floor
San Francisco, CA 941105

10 Complaint is extended to October 2, 2013.
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IT IS SO ORDERED.

12 Dated: September 26, 2013
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