Robert A. Bailey (# 214688), Kenneth A. Franklin (# 143809), ANGLIN, FLEWELLING, RASMUSSEN, CAMPBELL & TRYTTEN LLP, Pasadena, California, Attorneys for Defendant WELLS FARGO BANK, N.A., successor by merger with Wells Fargo Bank Southwest, N.A., f/k/a Wachovia Mortgage, FSB, f/k/a World Savings Bank, FSB (erroneously sued as "Wells Fargo Home Mortgage") ("Wells Fargo")
Robert Bloom, Attorney for Plaintiff, JO ANN KINSTON.
STIPULATION TO 1) EXTEND TIME TO FILE FIRST AMENDED COMPLAINT AND 2) TO CONTINUE THE CASE MANAGEMENT CONFERENCE AND [PROPOSED] ORDER
RICHARD SEEBORG, District Judge.
Plaintiff Jo Ann Kingston ("plaintiff"), and defendant Wells Fargo Bank, N.A., successor by merger with Wells Fargo Bank Southwest, N.A., formerly known as Wachovia Mortgage, FSB, formerly known as World Savings Bank, FSB ("Wells Fargo"), by and through their attorneys of record, hereby submit this stipulation and proposed order as follows:
WHEREAS, Plaintiff's first amended complaint is currently due on January 3, 2014. That date was established by stipulation of the parties and consent of the Court.
WHEREAS, a case management conference is currently scheduled for January 9, 2014.
WHEREAS, the parties have engaged in ADR with Daniel Bowling through the Court's ADR program. Whereas, a further ADR session is scheduled for January 16, 2014 with Mr. Bowling. Whereas, the parties desire to complete the ADR process before proceeding with the litigation; and
WHEREAS, the parties stipulate, subject to the Court's consent, that the first amended complaint shall be filed on or before January 30, 2014. The parties further request that the Court reschedule the case management conference to a date after the filing of the first amended complaint.
IT IS HEREBY STIPULATED as follows, subject to the Court's consent:
1. Plaintiff's first amended complaint shall be filed on or before January 30, 2014;
2. The case management conference shall be continued to a date after January 30, 2013 as the Court shall set.
IT IS SO ...