Removal Effected: 6/14/2011 Current response date: 7/21/2011 New response date: 7/27/2011
STIPULATION TO EXTEND TIME TO RESPOND TO INITIAL COMPLAINT6-1(a)) TO THE HONORABLE COURT, PLAINTIFF AND HIS COUNSEL OF RECORD:
Plaintiff Richard Pey and defendant Wachovia Mortgage, a division of Wells Fargo Bank,N.A., successor by merger with Wells Fargo Bank Southwest, N.A., formerly known asWachovia Mortgage, FSB, formerly known as World Savings Bank, FSB (sued herein as "Wachovia Mortgage Corporation; Wells Fargo Bank, N.A.") ("Wachovia") through their 6 respective counsel of record, hereby stipulate pursuant to Local Rule 6-1 to extend the date for Wachovia to respond to Plaintiff's initial Complaintto and including July 27, 2011, a date which 8 is not more than 30 days from the date a response initially would have been due. In return, Wachovia agreed to postpone the sale of the property at issue from June 29, 2011 to no earlier 10 than September 24, 2011, as plaintiff's motion for a preliminary injunction is scheduled to be 11 heard on September 23, 2011.
By this Stipulation, Defendant Wachovia does not waive its right to file a motion to dismiss as to the pending Complaint and Plaintiff does not waive his right to file a motion to 14 remand this action to state court. Wachovia agrees to not conduct a foreclosure sale of the 15 property until the Court rules on the motion for a preliminary injunction.
THE GOODELL LAW FIRM By: Nelson W. Goodell, Esq. email@example.com Attorneys for Plaintiff, Richard Pey Dated: July 21, 2011 ANGLIN, FLEWELLING, RASMUSSEN CAMPBELL & TRYTTEN LLP O By: ES DISTR T I T D U E R Raymond M. Collins 25 N IS SO ORDERED IT U A Attorneys for Defendant, 26 T firstname.lastname@example.org I N Wachovia Mortgage, a division of Wells Fargo N Samuel Conti R Bank, N.A., successor by merger with Wells Fargo 27 O Judge O R F Bank Southwest, N.A., formerly known as I Wachovia Mortgage, FSB, formerly known as DISTRICT O CASE NO. CV11 2922 LB W:\LITIG\95451\000909\00198259.DOC RN F World Savings Bank, FSB (sued herein as "Wachovia Mortgage Corporation; Wells Fargo Bank, N.A.") ("Wachovia")
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