STIPULATION TO EXTEND TIME FOR DEFENDANT TD BANK USA, NATIONAL ASSOCIATION TO RESPOND TO PLAINTIFF'S AMENDED COMPLAINT

MAXINE M. CHESNEY, District Judge.

Pursuant to Local Rules 6-1(a) and 6-2, Defendant TD Bank USA, National Association ("TD Bank") and Plaintiff Lacy Rose ("Plaintiff"), by and through their undersigned counsel of record, stipulate and agree as follows:

WHEREAS, on January 26, 2017, Plaintiff filed her initial complaint [Dkt. 1];

WHEREAS, TD Bank filed a Motion to Dismiss the Initial Complaint on March 17, 2017 [Dkt. 28];

WHEREAS, on April 7, 2017, Plaintiff filed and served an Amended Complaint [Dkt. 35]. Pursuant to F.R.C.P. 15(a)(3), TD Bank is to answer or otherwise respond to the Amended Complaint on or before April 21, 2017;

WHEREAS, to permit TD Bank sufficient time to evaluate the claims in the Amended Complaint and prepare an appropriate responsive pleading or motion, and for the parties to discuss a potential early resolution of the case, the parties have agreed to a forty-five day extension for TD Bank to answer or otherwise respond to the amended complaint up to and including June 5, 2017. The parties have been in the process of exchanging informal discovery. This extension will not affect any pending court dates or deadlines, nor will it prejudice any party herein. The Initial Case Management Conference is set for hearing on June 16, 2017, with the Joint Case Management Statement to be filed on or before June 9, 2017.

IT IS STIPULATED THAT TD Bank shall have up to and including June 5, 2017 to answer or otherwise respond to Plaintiff's Amended Complaint.

FILER ATTESTATION

Pursuant to Rule 5-1(i)(3) of the Local Rules of Practice in Civil Proceedings Before the United States District Court for the Northern District of California, I, Renee Choy Ohlendorf, hereby attest that concurrence in the filing of this document has been obtained from each of the other signatories.

I declare under penalty of perjury under the laws of the State of California and the United States of America that the foregoing is true and correct.