Lohse et al v. Nationstar Mortgage et al

Filing 7

ORDER Granting re 6 Stipulation as to Plaintiffs & Defendant Azatec To Extend Time filed by Aztec Foreclosure Corporation. Signed by Judge Joseph C. Spero on 3/3/14. (klhS, COURT STAFF) (Filed on 3/3/2014)

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ROBERTS & SHAPIRO, LLP
Keefe E. Roberts, Esq. Bar No. 212643
Email: [e-mail]
Jenna M. Warden, Esq. Bar No. 286511
Email: [e-mail]
6 Venture, Suite 305
Irvine, California 92618
Tel: [phone]
Fax: [phone]
Attorneys for Defendant,
AZTEC FORECLOSURE CORPORATION

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

KEEFE ROBERTS & ASSOCIATES
6 Venture, Suite 305
Irvine, CA, 92618

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GARY LOHSE and HANNEKE LOHSE,

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Plaintiff,

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Case No. 3:14-cv-00514-JCS

v.
NATIONSTAR MORTGAGE, LLC;
AZTEC FORECLOSURE
CORPORATION; and DOES 1 through
10, inclusive,

PLAINTIFFS AND DEFENDANT
AZTEC FORECLOSURE
CORPORATION’S JOINT
STIPULATION TO EXTEND TIME
TO RESPOND TO COMPLAINT
L.R. 6-1(a)

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Defendants.
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Plaintiffs, GARY LOHSE and HANNEKE LOHSE (“Plaintiffs”) on the one hand, and
Defendant, AZTEC FORECLOSURE CORPORATION (“Defendant”), on the other hand,

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through their respective attorneys on record, jointly stipulate as follows:
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WHEREAS Defendant was served with the Complaint on February 7, 2014;
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WHEREAS Defendant’s responsive pleading is currently due on or before February 28,
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2014;
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WHEREAS Plaintiffs and Defendant are engaging in discussions regarding the merits of
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the Complaint that may lead to settlement of the lawsuit.
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PLAINTIFF’S AND DEFENDANTS’ JOINT STIPULATION TO EXTEND TIME TO RESPOND TO
COMPLAINT
(Andreini, et al. v. Blake, et al.)

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THE PARTIES HEREBY STIPULATE THAT:

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1. Pursuant to Local Rule 6-1(a), Defendant’s deadline to respond to the Complaint in

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this action is extended from February 28, 2014to March 14, 2014.

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Dated: February 27, 2014

PRICE LAW GROUP, APC

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By: _/s/ G. Thomas Martin, III, Esq._____
G. Thomas Martin, III, Esq.
Attorney for Plaintiffs, GARY LOHSE and
HANNEKE LOHSE

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Dated: February 27, 2014

ROBERTS & SHAPIRO, LLP

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ER

R NIA

S

seph C.

Judge Jo

H

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RT

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ED

ORDER

Spero

LI

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O
IT IS S

A

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Dated: 3/3/14

UNIT
ED

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ISTRIC
ES D
TC
AT
T

RT
U
O

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By: _/s/ Jenna M. Warden _________
Jenna M. Warden
Attorney for Defendant, AZTEC
FORECLOSURE CORPORATION

FO

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NO

KEEFE ROBERTS & ASSOCIATES
6 Venture, Suite 305
Irvine, CA 92618

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N

F
D IS T IC T O
R

C

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-2PLAINTIFFS’ AND DEFENDANT AZTEC FORECLOSURE CORPORATION’S JOINT STIPULATION TO
EXTEND TIME TO RESPOND TO COMPLAINT

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PROOF OF SERVICE
(C.C.P. §§1013(a) and 2015.5)
I, the undersigned, declare:
I am over the age of 18 and not a party to the within action. My business address is 6
Venture, Suite 305, Irvine, California 92618.

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On February 28, 2014 I served true and correct copies of the following document(s):
PLAINTIFFS AND DEFENDANT AZTEC FORECLOSURE CORPORATION’S JOINT
STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT, on the interested
parties in this action as follows:

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SEE ATTACHED SERVICE LIST

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() By Regular Mail: I caused copies of such document, enclosed in sealed envelopes, to be
deposited in the mail at Irvine, California, with postage thereon fully prepaid to the persons and
addresses indicated on the attached service list. I am “readily familiar” with the firm’s practice of
collecting and processing correspondence for mailing. It is deposited with U.S. Postal Service on
that same day in the ordinary course of business. I am aware that on motion of any party served,
service presumed invalid if the postal cancellation date or postage meter date is more than one
day after the date of deposit for mailing set forth in this affidavit.

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KEEFE ROBERTS & ASSOCIATES
6 Venture, Suite 305
Irvine, CA 92618

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(✓) By Electronic Service: By electronically transmitting such document(s) in .pdf or other
computer readable format, pursuant to C.C.P. §1010.6 and C.R.C., Rule 2.260, from email
address: * to the parties (who have agreed to service by electronic mail in this action) and at the
email addresses indicated on the attached Service List. No electronic delivery report indicating
non-receipt or incomplete transmission was received, or, a read/delivery receipt was received
indicating successful transmission to each such party.
( ) By Personal Service: I caused such document(s) to be delivered by hand to the above
address(es).
(_) By Overnight Courier: I caused the above-referenced document(s) to be delivered to a
courier service (Federal Express) for delivery the next business day to the above address(es).
( ) By Facsimile Machine: I caused the above-referenced document(s) to be transmitted during
normal business hours from Fax telephone number(s) [phone] to the person(s) and at the
Fax telephone number(s) indicated on the attached Service List. A Fax “Transmission Report”
confirming successful, error-free transmission was received for each such party.
Executed on February 28, 2014 at Irvine, California.
(✓) (State) I declare under penalty of perjury under the laws of the State of California that the
foregoing is true and correct.
(_) (Federal) I declare that I am employed in the office of a member of the bar of this court at
whose direction this service was made.

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/s/ Jenna Warden
Jenna Warden

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-3PLAINTIFFS’ AND DEFENDANT AZTEC FORECLOSURE CORPORATION’S JOINT STIPULATION TO
EXTEND TIME TO RESPOND TO COMPLAINT

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SERVICE LIST
G. Thomas Martin, III, Esq.
PRICE LAW GROUP, APC
ECF

Attorney for Plaintiffs

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KEEFE ROBERTS & ASSOCIATES
6 Venture, Suite 305
Irvine, CA 92618

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-4PLAINTIFFS’ AND DEFENDANT AZTEC FORECLOSURE CORPORATION’S JOINT STIPULATION TO
EXTEND TIME TO RESPOND TO COMPLAINT