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Ross v. Wells Fargo Bank

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA


July 1, 2009

SUE ANN ROSS, PLAINTIFF,
v.
WELLS FARGO BANK, N.A., FIRST AMERICAN TITLE INSURANCE COMPANY, FIRST AMERICAN LOANSTAR TRUSTEE SERVICES, WELLS FARGO HOME MORTGAGE, MORTGAGE ELECTRONIC / REGISTRATION SYSTEMS, INC, AND DOES 2-50, INCLUSIVE, DEFENDANTS.

STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE THIRD AMENDED COMPLAINT

Pursuant to Fed. R. Civ. P. 15 and Local Rule 15-220, plaintiff Sue Ann Ross ("Plaintiff") and defendants Wells Fargo Home Mortgage, Inc., a division of Wells Fargo Bank, N.A. ("Wells Fargo") (collectively "the Parties"), by and through their respective counsel, have met and conferred concerning certain claims and allegations in the Second Amended Complaint.

Wherefore, the Parties stipulate and agree that good cause exists for Plaintiff to file the attached Third Amended Complaint ("TAC"). It is further stipulated that Wells Fargo will file and serve its response to the TAC 30 days after entry of this Order.

This stipulation is without prejudice to the rights, claims, defenses and arguments of all parties.

Pursuant to the stipulation and good cause appearing,

IT IS SO ORDERED.

CERTIFICATE OF SERVICE

I hereby certify that on June 27, 2009 I have electronically filed the foregoing with the Clerk of Court using the CM/ECF system, which will then send a notification of such filing (NEF) to the following:

Mr. Joshua Whitehair Severson & Werson One Embarcadero Center, Suite 2600 San Francisco, CA 94111 Jonathan G. Stein Signature of sending party

20090701

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