Velasquez v. Bank of America N.A. et al

Filing 27

STIPULATION AND ORDER. Signed by Judge ARMSTRONG on 10/28/11. (lrc, COURT STAFF) (Filed on 10/31/2011)

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IN THE UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA – OAKLAND DIVISION

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

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10 RODOLFO VELASQUEZ,

Case No. 4:11-CV-02491-SBA

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Hon. Saundra Brown Armstrong
Presiding

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Plaintiff,
v.

BANK OF AMERICA N.A.,
14 LTD FINANCIAL SERVICES, L.P.,

STIPULATION AND [PROPOSED]
ORDER TO GIVE PLAINTIFF
LEAVE TO AMEND TO FILE A
FIRST AMENDED COMPLAINT

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Complaint filed May 23, 2011

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Defendants.

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Plaintiff RODOLFO VELASQUEZ and Defendant BANK OF AMERICA, N.A.

18 hereby stipulate that:
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WHEREAS, this action was originally filed on May 23, 2011,

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WHEREAS, Defendant BANK OF AMERICA, N.A. has filed a motion to dismiss

21 the Complaint on Jun e 15, 2011;
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WHEREAS, the parties have met and conferred about the issues raised in the

23 aforementioned motion to dismiss;
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WHEREAS, Plaintiff wishes to amend his complaint to add COUNTRYWIDE

25 HOME LOANS, INC. as a Defendant, add four new causes of action for Quiet Title,
26 Declaratory and Injunctive Relieve, Intentional Infliction of Emotional Distress, and Quasi
27 Contract;
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WHEREFORE, Plaintiff proposes to file his amended complaint within 21 days of

2 the date of this ORDER; and
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WHEREFORE, Defendant BANK OF AMERICA, N.A. shall have 21 days from

4 the date the First Amended Complaint is filed to answer, move to dismiss, or otherwise
5 respond to Plaintiff’s First Amended Complaint.
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DATED: October ____, 2011

PLAINTIFF, IN PRO PER

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By:

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

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Rodolfo Velasquez

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11 DATED: October 25, 2011

BRYAN CAVE LLP

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By: /s/ Jessica T. Ehsanian
Jessica T. Ehsanian
Attorneys for Defendant Bank of America,
N.A.

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ORDER

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Based on the stipulation of the parties and good cause showing, IT IS HEREBY

3 ORDERED that Plaintiff may file a First Amended Complaint with the changes detailed
4 above within 21 days of the date of this ORDER. Defendants shall file a responsive
5 pleading within 21 days of the filing of the First Amended Complaint.
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IT IS SO ORDERED.

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8 Dated: 10/28/11____

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

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Hon. Saundra B. Armstrong, District Court Judge
United States District Court
Northern District of California

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UNITED STATES DISTRICT COURT
2 FOR THE
NORTHERN DISTRICT OF CALIFORNIA
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4 RODOLFO VELASQUEZ,
Plaintiff,

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v.

7 BANK OF AMERICA et al,
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Defendant.
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Bryan Cave LLP
Two Embarcadero Center, Suite 1410
201 Clay Street
San Francisco, CA 94111-3907

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Case Number: CV11-02491 SBA

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CERTIFICATE OF SERVICE

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I, the undersigned, hereby certify that I am an employee in the Office of the Clerk, U.S. District
13 Court, Northern District of California.
14 That on October 31, 2011, I SERVED a true and correct copy(ies) of the attached, by placing said
copy(ies) in a postage paid envelope addressed to the person(s) hereinafter listed, by depositing
15 said envelope in the U.S. Mail, or by placing said copy(ies) into an inter-office delivery receptacle
located in the Clerk's office.
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Rodolfo Velasquez
19 426 Idora Avenue
Vallejo, CA 94591
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Dated: October 31, 2011
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Richard W. Wieking, Clerk

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CLARK, Deputy Clerk

By: LISA R

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