STIPULATION AND ORDER EXTENDING TIME FOR PARTIES TO RESPOND TO DISCOVERY REQUESTS AND EXTENDING THE FACT-DISCOVERY CUT-OFF FOR THAT PURPOSE

MORRISON C. ENGLAND, Jr., District Judge.

Plaintiff and Defendants GMAC MORTGAGE, LLC, ("GMAC") and UNITED STATES OF AMERICA ("U.S.") (collectively, "Parties") hereby stipulate as follows and request that the court enter the proposed order set forth below.

WHEREAS, trial of this case is scheduled to begin on July 2, 2012;

WHEREAS, the fact-discovery cut-off is September 16, 2011;

WHEREAS, on August 11, 2011, Plaintiff propounded the following discovery requests upon Defendant GMAC: (1) Requests for Production of Documents Propounded by Plaintiff Bank of America, N.A., to Defendant GMAC Mortgage, LLC, Set One; (2) Interrogatories Propounded by Plaintiff Bank of America N.A., to Defendant GMAC Mortgage, LLC, Set One; (3) Requests for Admission Propounded by Plaintiff Bank of America N.A., to Defendant GMAC Mortgage, LLC, Set One ("BofA's Discovery");

WHEREAS, on August 13, 2011, GMAC propounded the following discovery requests upon Plaintiff: (1) Defendant GMAC's Request for Production of Documents and Electronically Stored Information and Things to Plaintiffs, Set One; (2) Defendant GMAC's Interrogatories too Plaintiff, Set One; and (3) Defendant GMAC's Requests for Admission to Plaintiff, Set One ("GMAC's Discovery");

WHEREAS, Plaintiff and Defendant GMAC and their attorneys require additional time beyond the discovery cut-off to adequately and properly respond to GMAC's Discovery and BofA's Discovery; and,

WHEREAS, the Parties believe that a short extension of time for Plaintiff's and Defendant GMAC's responses beyond the discovery cut-off will not interfere with any litigation dates, schedules, or deadlines in this action.

NOW, THEREFORE, the Parties stipulate and agree that, notwithstanding the fact discovery cut-off date, Plaintiff and Defendant GMAC shall have up to and including September 29, 2011, to serve their responses to GMAC's Discovery and to BofA's Discovery, respectively, and that the fact discovery cut-off shall be extended to September 29, 2011 for this purpose alone.

IT IS SO STIPULATED.

ORDER

The Court, having reviewed the foregoing stipulation, and good cause appearing therefore, by ORDERS that Plaintiff and Defendant GMAC shall have up to and including September 29, 2011, to serve their responses to GMAC's Discovery and to BofA's Discovery, respectively, and he fact discovery cut-off shall be extended to September 29, 2011 for this purpose alone.

IT IS SO ORDERED.