STIPULATION TO EXTEND TIME FOR DEFENDANT JPMORGAN CHASE BANK, N.A. TO RESPOND TO PLAINTIFF'S SECOND AMENDED COMPLAINT AND ORDER

TROY L. NUNLEY, District Judge.

Plaintiff Vladimir Rivkin ("Plaintiff") and Defendant JPMorgan Chase Bank, N.A. ("JPMC" and with Plaintiff, the "Parties"), hereby enter into this Stipulation to Extend Time for Defendant to Respond to Plaintiff's First Amended Complaint with reference to the following facts:

RECITALS

A. On or about October 16 2014, Plaintiff commenced an action in the Superior Court for the County of Nevada entitled Rivkin v. JPMorgan Chase Bank, N.A., et al., Case Number TCU14-5931 (the "State Court Action").

B. On or around October 23, 2014, Plaintiff served the Summons and First Amended Complaint on JPMC.

C. On November 14, 2014, JPMC timely removed the State Court Action to this Court.

D. On November 25, 2014, the Parties entered into a stipulation to extend the time for JPMC to respond to the First Amended Complaint to allow the Plaintiff and co-defendant Fay Servicing LLC to engage in discussions regarding the then pending Trustee's Sale and in view of the possibility of Plaintiff filing a second amended complaint.

E. On January 8, 2015, Plaintiff filed a request for leave to file a second amended complaint. (Docket No. 21.)

F. On January 21, 2015, the Parties entered into a further stipulation to extend the time for JPMC to respond to the First Amended Complaint in view of Plaintiff's pending request for leave to file a second amended complaint. (Docket No. 25.) The Court entered an order approving the Parties' stipulation on January 22, 2015. (Docket No. 26.)

G. The Parties then entered into four further stipulations to extend the time for JPMC to respond to the First Amended Complaint in view of Plaintiff's pending request for leave to file a second amended complaint and their ongoing settlement discussions. (Docket Nos. 27, 31, 36 & 38.) The Court entered orders approving the Parties' stipulations. (Docket Nos. 28, 32, 37, & 39.)

H. On September 3, 2015, JPMC filed a motion to dismiss the First Amended Complaint (the "Motion"). (Docket. No. 40).

I. The Court took the Motion under submission on October 6, 2015. (Docket No. 45).

J. In late August of 2016, the primary attorney handling this matter for JPMC, Joseph Quattrocchi, passed away.

K. On October 18, 2016, the Court granted the Motion but permitted Plaintiff to file an amended complaint.

M. To provide new counsel for JPMC sufficient time to review the matter and prepare a response to the Second Amended Complaint, the Parties have agreed to extend JPMC's deadline for responding to the Second Amended Complaint up to and including December 9, 2016.

IT IS THEREFOR STIPULATED that JPMC shall have up to and including December 9, 2016 to respond to Plaintiff's Second Amended Complaint.

ORDER

IT IS SO ORDERED.