Ravan et al v. American Mortgage Express Corp et al

Filing 21

STIPULATION AND ORDER re 20 Stipulation filed by Bank of America Corporation, Bank of America, N.A., Bank of America Home Loans Servicing, L.P.. Signed by Judge Edward M. Chen on 9/14/11. (bpf, COURT STAFF) (Filed on 9/14/2011)

1 BRYAN CAVE LLP
C. Scott Greene, California Bar No. 277445
2 Alison V. Lippa , California Bar No. 160807
Joseph V. Quattrocchi, California Bar No. 257568
3 Two Embarcadero Center, Suite 1410
San Francisco, CA 94111
4 Telephone: [phone]
Facsimile:
415-675-3434
[e-mail]
5 E-Mail:
[e-mail]
[e-mail]
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BANK OF AMERICA, N.A. as successor by merger to BAC HOME LOANS SERVICING,
8 L.P. and BANK OF AMERICA CORPORATION

Bryan Cave LLP
Two Embarcadero Center, Suite 1410
San Francisco, CA 94111-3907

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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MEHDI RAVAN and ALI RAVAN,

Case No. 3:11-CV-02371 EMC

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Plaintiffs,
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v.
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AMERICAN MORTGAGE EXPRESS
16 CORP; BANK OF AMERICA HOME
LOANS SERVICING, L.P.; BANK OF
17 AMERICA CORPORATION; and DOES 1100, inclusive,
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Defendants.
19

JOINT STIPULATION EXTENDING
DEFENDANTS’ TIME TO RESPOND TO
COMPLAINT ; ORDER
[L.R. 6-1(a)]
DATE ACTION FILED: APRIL 7, 2011
TRIAL DATE: NOT YET ASSIGNED

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SF01DOCS\44517.1
JOINT STIPULATION EXTENDING DEFENDANTS’ TIME TO RESPOND – CASE NO. 3:11-CV-02371 EMC

STIPULATION

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Defendants Bank of America, N.A., as successor by merger to BAC Home Loans

2

3 Servicing, L.P. and Bank of America Corporation (“Defendants”), and Plaintiffs Mehdi Ravan and
4 Ali Ravan (“Plaintiffs”), by and through their counsel of record, hereby stipulate and agree as
5 follows:
1.

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Defendant BAC Home Loans Servicing, L.P. removed this matter from Alameda

7 County Superior Court on May 13, 2011.
2.

8

Plaintiffs and Defendants are in the process of discussing the informal resolution of

Bryan Cave LLP
Two Embarcadero Center, Suite 1410
San Francisco, CA 94111-3907

9 this matter.
3.

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In order to continue the current settlement discussions, reduce cost of litigation for

11 both parties, and potentially unburden the Court’s docket, Plaintiffs grant Defendants an extension
12 to respond to their Complaint. Thus, instead of responding to the Complaint on September 16,
13 2011, the parties agree that Defendants’ time to file and serve their response to the Complaint is
14 extended up to and including November 15, 2011. This stipulation will not alter any pre-existing
15 court event or deadline, and is submitted without a court order pursuant to Local Rule 6-1(a).
4.

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The stipulation will not result in prejudice to any party and its impact on judicial

17 proceedings is not expected to be significant.
5.

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Nothing in this stipulation shall constitute a waiver of any arguments or defenses

19 that Defendants or Plaintiffs may wish to assert in their pleadings, all of which are expressly
20 reserved.
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SF01DOCS\44517.1
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JOINT STIPULATION EXTENDING DEFENDANTS’ TIME TO RESPOND – CASE NO. 3:11-CV-02371 EMC

1 IT IS SO STIPULATED.
2
3 Dated: September 13, 2011

MATRIX LAW FIRM, APC
Reuben D. Nathan

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By:

/s/ Reuben D. Nathan
Reuben D. Nathan
Attorney for Plaintiffs
MEHDI RAVAN and ALI RAVAN

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BRYAN CAVE LLP
C. Scott Greene
Alison V. Lippa
Joseph V. Quattrocchi

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By:

/s/ Joseph V. Quattrocchi
Joseph V. Quattrocchi
Attorneys for Defendants
BANK OF AMERICA, N.A. as successor by
merger to BAC HOME LOANS SERVICING,
L.P., AND BANK OF AMERICA
CORPORATION

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RT

ER

R NIA

A

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FO

NO

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ED

_________________ SO ORDER
IT IS
Edward M. Chen
M. Chen
U.S. District Judge Judge Edward

LI

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S DISTRICT
TE
C
TA

RT
U
O

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IT IS SO ORDERED:
S

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UNIT
ED

Bryan Cave LLP
Two Embarcadero Center, Suite 1410
San Francisco, CA 94111-3907

Dated: September 13, 2011
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D IS T IC T O
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JOINT STIPULATION EXTENDING DEFENDANTS’ TIME TO RESPOND – CASE NO. 3:11-CV-02371 EMC