Jeanette et al v. Bank of America, N.A. et al

Filing 21

STIPULATION AND ORDER GRANTING EXTENSION OF TIME FOR DEFENDANTS TO ANSWER PLAINTIFFS' FIRST AMENDED COMPLAINT re 20 Stipulation filed by BAC Home Loans Servicing, LP, Bank of America, N.A. Signed by Judge Paul S. Grewal on June 14, 2011. (psglc1, COURT STAFF) (Filed on 6/14/2011)

1
2
3
4
5
6
7

BRYAN CAVE LLP
Andrea Hicks, California Bar No. 219836
Michael J. Peng, California Bar No. 260852
2 Embarcadero Center, Suite 1410
San Francisco, CA 94111
Telephone:
[phone]
Facsimile:
[phone]
Email:
[e-mail]
[e-mail]
Attorneys for Defendants
BANK OF AMERICA, N.A. and BAC HOME LOANS SERVICING, LP
UNITED STATES DISTRICT COURT

9
Bryan Cave LLP
Two Embarcadero Center, Suite 1410
201 Clay Street
San Francisco, CA 94111-3907

8

NORTHERN DISTRICT OF CALIFORNIA – SAN JOSE DIVISION

10 DONALD JEANETTE AND GERDA
GREENBAND, husband and wife,
11
Plaintiffs,
12
v.

Case No. CV11-1052-PSG
JOINT STIPULATION EXTENDING
DEFENDANTS’ TIME TO ANSWER
PLAINTIFFS’ FIRST AMENDED
COMPLAINT

13 BANK OF AMERICA, N.A., A DELAWARE
CORPORATION; BAC HOME LOANS
14 SERVICING, LP, a Texas Limited
Partnership; and DOES 1 THROUGH 100,
15 inclusive,
16

[L.R. 6-1(a)]

Defendants.

17
STIPULATION

18
19

Defendants Bank of America, N.A. and BAC Home Loans Servicing, LP, (“Defendants”)

20 and Plaintiffs Donald Jeanette and Gerda Greenband (“Plaintiffs”) by and through their counsel of
21 record, hereby stipulate and agree as follows:
22

1. Plaintiffs filed their Complaint with the Superior Court of California, County of Santa

23 Cruz on December 22, 2010;
24

2. On March 7, 2011, this action was removed to the United States District Court,

25 Northern District of California;
26

3. On March 10, 2011, Plaintiffs, by and through their undersigned counsel, agreed to

27 Defendants’ request to extend their answer period fourteen (14) days to March 28, 2011, in an
28 effort to explore settlement negotiations and avoid unnecessary costs of litigation and burden on
1
STIPULATION EXTENDING DEFENDANTS’ TIME TO ANSWER PLAINTIFFS’ FIRST AMENDED COMPLAINT

1 the Court’s docket;
2

4. On May 27, 2011, pursuant to a stipulation between Plaintiffs, by and through their

3 undersigned counsel, and Defendants, by and through their undersigned counsel, Plaintiffs filed
4 their First Amended Complaint with Defendants’ responsive pleading deadline being June 14,
5 2011.
6

5. Given the current stages of on-going settlement negotiations between the Plaintiffs, by

7 and through their undersigned counsel, and Defendants, by and through their undersigned counsel,
8 the parties jointly agree and stipulate to extend Defendants’ period to file a responsive pleading to

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

9 Plaintiffs’ Complaint First Amended in this action to August 1, 2011;
10

6. The Parties have concluded that this stipulated extension shall not prejudicially impact

11 any scheduled judicial proceedings in this action.
12

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

13 Defendants or Plaintiffs may wish to assert in their pleadings, all of which are expressly reserved.
14
15

PURSUANT TO STIPULATION, IT IS SO ORDERED.

Date: June___, 2011
14

16

_______________________________________
Magistrate Judge Paul Singh Grewal

17
18
19 Dated: June 13, 2011

LAW OFFICES OF JASON PINTAR
Alan Liang
By:

24

/s/ Alan Liang
Alan Liang
Attorney for Plaintiffs
DONALD JEANETTE AND GERDA
GREENBAND
BRYAN CAVE LLP
Andrea M. Hicks
Michael J. Peng

25

By:

20
21
22
23 Dated: June 13, 2011

26
27

/s/ Michael J. Peng
Michael J. Peng
Attorneys for Defendants
BANK OF AMERICA, N.A. AND BAC HOME
LOANS SERVICING, LP

28
2
STIPULATION EXTENDING DEFENDANTS’ TIME TO ANSWER PLAINTIFFS’ FIRST AMENDED COMPLAINT