STIPULATION AND ORDER EXTENDING DEFENDANTS' TIME TO RESPOND TO THE AMENDED COMPLAINT AND MODIFYING BRIEFING SCHEDULE

DUNCAN W. KEIR, Bankruptcy Judge.

WHEREAS, on April 29, 2011, Plaintiffs Joel I. Sher, Chapter 11 Trustee, and Zuni Investors, LLC (together, "Plaintiffs") filed a Complaint, captioned Joel I. Sher, et ano. v. Countrywide Home Loans, Inc., et ano., Adversary Proceeding No. 11-00337, pending in the United States Bankruptcy Court for the District of Maryland, Baltimore Division;

WHEREAS, on July 8, 2011, defendant Countrywide Home Loans, Inc. ("Countrywide") and defendant Bank of America Corporation (collectively, "Defendants") filed motions to dismiss the Complaint;

WHEREAS, on July 9, 2011, Countrywide filed a motion to transfer venue of this adversary proceeding to the U.S. District Court for the Central District of California (the "Venue Motion") and a motion to withdraw the reference of the Plaintiffs' Complaint (the "Motion to Withdraw the Reference");

WHEREAS, on July 29, 2011 Plaintiffs filed an Amended Complaint for Breach of Contract (the "Amended Complaint");

WHEREAS, the parties agreed to extend Defendants' time to move, answer, or otherwise respond to the Amended Complaint until September 2, 2011, and to a further schedule for filing of oppositions to the motions and replies thereto;

WHEREAS, the parties have now agreed that Defendants' time to move, answer, or otherwise respond to the Amended Complaint should be extended by an additional week, until September 9, 2011;

WHEREAS, the parties have agreed that Plaintiffs should have until September 30, 2011 to respond to Defendants' motions to dismiss, should Defendants so move;

WHEREAS, the parties have agreed that Defendants should have until October 10, 2011 to reply to Plaintiffs' oppositions to Defendants' motion(s) to dismiss;

WHEREAS, the parties have agreed that Defendants should have until September 9, 2011 either to file a new Venue Motion and new Motion to Withdraw the Reference or to advise the Plaintiffs that Defendants will stand on those motions as filed on July 9, 2011;

WHEREAS, the parties have agreed that Plaintiffs should have until September 30, 2011 to respond to the Venue Motion and the Motion to Withdraw the Reference;

WHEREAS, the parties have agreed that Defendants should have until October 10, 2011 to reply to Plaintiffs' oppositions to Defendants' Venue Motion and Motion to Withdraw the Reference; and

WHEREAS, each party has reserved all rights with respect to additional extensions of Defendants' time to move, answer or otherwise respond to the Amended Complaint, including (without limitation) the parties' rights both to seek the Court for such an additional extensions and to oppose such requests.

IT IS HEREBY FURTHER STIPULATED AND AGREED, by the undersigned parties, by and through their attorneys, that the time for Defendants Countrywide Home Loans, Inc. and Bank of America Corporation to move, answer, or otherwise respond to the Amended Complaint is hereby extended to and including September 9, 2011; that Plaintiffs Chapter 11 Trustee and Zuni Investors, LLC shall have until September 30, 2011 to oppose Defendants' motions, should Defendants so move; and that Defendants shall have until October 10, 2011 to reply to Plaintiffs' opposition motions; and that the same schedules shall be followed with respect to briefing of the Venue Motion and Motion to Withdraw the Reference .

SO ORDERED.