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Adame v. Bank of America

April 14, 2010

RICHARD ADAME, CONNIE G. BENDER, AND CONSTANCE DAVIS PLAINTIFF,
v.
BANK OF AMERICA, NATIONAL ASSOCIATION (ERRONEOUSLY SUED AS "BANK OF AMERICA") DEFENDANT.



The opinion of the court was delivered by: Judge: Hon. Susan Illston

STIPULATED REQUEST TO RESERVE HEARING DATES FOR DEFENDANT'S MOTIONS FOR SUMMARY JUDGMENT

STIPULATION

1. Defendant Bank of America, N.A. intends to file three motions for summary judgment (one as to each Plaintiff).

2. The parties hereto through their respective attorneys of record hereby stipulate and agree to set the hearings for Defendant's first motion for on June 11, 2010 at 9:00 a.m. The motion will follow the regular briefing schedule.

3. The parties hereto through their respective attorneys of record hereby stipulate and agree to set the hearings for Defendant's second motion for July 16, 2010 at 9:00 a.m. The motion will follow the regular briefing schedule.

4. The parties hereto through their respective attorneys of record hereby stipulate and agree to set the hearings for Defendant's third motion for September 17, 2010 at 9:00 a.m. Defendant's opening brief shall be filed on or before July 23, 2010. Plaintiff's brief in opposition shall be filed on or before August 6, 2010. Defendant's reply brief shall be filed on or before September 3, 2010.

5. Both parties agree to the stipulation as indicated by their signatures below. The parties respectfully request that the Court approve the Stipulation and enter an Order thereupon. A form of proposed Order is filed herewith.

Respectfully submitted,

Dated: April 12, 2010

J. GARY GWILLIAM

RANDALL E. STRAUSS

GWILLIAM, IVARY, CHIOSSO, CAVALLI & BREWER

Randall E. Strauss Attorneys for Plaintiffs Richard Adame, Connie G. ...


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