JOINT EX PARTE STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT TO RESPONSE TO THE COMPLAINT; ORDER

([Proposed] Order Contained Herein)

ERICA P. GROSJEAN, Magistrate Judge.

TO THE HONORABLE COURT:

IT IS HEREBY STIPULATED by and between defendant JPMORGAN CHASE BANK, N.A. (ERRONEOUSLY SUED AS "JP MORGAN CHASE BANK, N.A., INC.") ("Chase") and plaintiff Samir Ibrahim Marcoss ("Marcoss") by any between their respective counsel as follows:

1. WHEREAS, on February 9, 2018 this action was filed in the Superior Court of California — County of Fresno.

2. WHEREAS, on March 9, 2018 the summons and complaint were served on Chase.

3. WHEREAS, on April 9, 2018 Chase caused this action to be removed to the United States District Court for the Eastern District of California where this matter as assigned Case No. 1:18-at-00266.

4. WHEREAS, Chase's response to the complaint would ordinarily be due on or before April 16, 2018.

5. WHEREAS, Chase and Marcoss mutually desire to attempt to resolve this matter prior to the effort and expense of formally responding to the Complaint.

6. WHEREAS, on April 9, 2018 Chase and Marcoss, via counsel, agreed to an extension/enlargement of the time to respond to the complaint by twenty-eight (28) days pursuant to Eastern District of California Local Rule 144 through and including May 14, 2018 (Dkt. No. 4).

7. WHEREAS, on April 10, 2018 the Court set the Mandatory Scheduling Conference ("MSC") for July 19, 2018 ("MSC Date").

8. WHEREAS, Chase and Marcoss are continuing their dialogue regarding possible settlement.

9. WHEREAS, Chase and Marcoss have agreed to continue said settlement discussions through and including June 15, 2018 and mutually desire that Chase's response to the Complaint be due on or before June 15, 2018, which date is before the MSC Date, pursuant to Eastern District of California Local Rule 144.

10. WHEREAS, both Chase and Marcoss jointly apply to the Court on an ex parte basis for an Order setting Chase's response to the Complaint as June 15, 2018.

NOW THEREFORE, IT HEREBY STIPULATED AND AGREED BY AND BETWEEN THE UNDERSIGNED COUNSEL FOR THE PARTIES HERETO:

Chase and Marcoss stipulate to extend Chase's time to respond to the complaint from May 14, 2018 to June 15, 2018.

IT IS SO STIPULATED.

ORDER

Based on the above stipulation of the parties, and good cause appearing, Chase's time to respond to the complaint is extended from May 14, 2018 to June 15, 2018.