STIPULATION AND PROPOSED ORDER EXTENDING TIME TO RESPOND TO COMPLAINT

WILLIAM B. SHUBB, District Judge.

This Stipulation is entered into by and between Defendant CitiMortgage, Inc. ("Citi"), and Plaintiffs David T. Heydt and Jennifer F. Heydt (the "Plaintiffs," and collectively with Citi, the "Parties"), as follows:

RECITALS

A. On April 27, 2015, Plaintiffs filed their Complaint (the "Complaint") against Citi and others.

B. On May 15, 2015, Plaintiffs served their Complaint on Citi's registered agent, making June 5, 2015 Citi's present deadline to respond to the Complaint.

C. Given the number of issues in the 157-paragraph, 6-count Complaint and the schedule of counsel for the Parties, the Parties have conferred and agreed to extend Citi's time for responding to the Complaint through and including July 20, 2015.

D. Citi has not previously requested any extensions of time in this case, and except as described herein, this Stipulation will have no effect on the schedule for this case.

AGREEMENT

NOW, THEREFORE, based upon the foregoing and subject to Court approval, the Parties hereby STIPULATE AND AGREE AS FOLLOWS:

1. The Parties incorporate by reference each of the Recitals contained in paragraphs A through D hereinabove as if set forth in full herein.

2. The time for Citi to move, answer or otherwise respond to the Complaint is extended to and includes July 20, 2015.

3. The Parties agree that by entering into this Stipulation, neither Party waives any right or remedy.