STIPULATION TO PERMIT PLAINTIFF TO FILE SECOND AMENDED COMPLAINT AND ORDER

VINCE CHHABRIA, District Judge.

Plaintiff Barbara Clark, fka Barbara Hopkins ("Plaintiff") and Defendants JPMorgan Chase & Co., Chase Manhattan Mortgage Corporation, Chase Home Finance, LLC, and JPMorgan Chase Bank N.A. (collectively "Defendants", and together with Plaintiff, the "Parties"), by and through their attorneys of record, hereby enter into the following agreement and request for order thereon:

1. As the Parties are engaged in negotiations to resolve and settle all issues between them, and pursuant to FRCP 15(a)(1)(B), Defendants consent to permit Plaintiff to file a Second Amended Complaint. The Second Amended Complaint shall be filed on or before August 28, 2014.

2. Defendants further agree to withdraw the pending Motion to Dismiss without prejudice to file a later motion based on the sufficiency of the Second Amended Complaint and to that end, ask the court to vacate the hearing on the motion set for August 28, 2014 and the briefing schedule set on the motion.

3. Plaintiff agrees to extend to Defendants the opportunity to file an answer or otherwise respond to the Second Amended Complaint, to September 28, 2014, thirty (30) days after deadline for filing the Second Amended Complaint.

4. With the Second Amended Complaint time table agreed to by the parties, they hereby request that the Case Management Conference set for August 28, 2014 be continued to late October or November 2014.

[PROPOSEDORDER

Pursuant to the stipulation of the parties, IT IS SO ORDERED. A case management conference is scheduled for October 30, 2014, at 10:00 a.m. A joint case management statement is due no later than October 23, 2014.