STIPULATION TO EXTEND DEADLINE FOR PLAINTIFF TO FILE AN AMENDED COMPLAINT; [PROPOSED] ORDER

Civil Local Rule 6-2

JON S. TIGAR, District Judge.

Pursuant to Civil L.R. 6-1(b), 6-2, and 7-12, Plaintiff Margo Perryman ("Plaintiff"), and Defendants Litton Loan Servicing, LP and American Modern Home Insurance Company ("American Modern"), through their respective attorneys, stipulate as follows:

WHEREAS, on August 19, 2015, this Court held a Case Management Conference and set a deadline of November 19, 2015 for Plaintiff to file a Second Amended Complaint (Dkt. No. 212);

WHEREAS, prior to amending her Complaint, Plaintiff contends she requires certain documents and/or testimony from non-party Southwest Business Corporation ("SWBC");

WHEREAS, on October 9, Plaintiff served a subpoena to obtain documents and testimony from SWBC;

WHEREAS, as of the date of this stipulation, Plaintiff contends that SWBC has not produced all documents and information responsive to the subpoena;

WHEREAS, Defendant American Modern has also entered into a settlement in principle in a parallel, partially overlapping class action pending in the Southern District of New York, captioned Lyons v. Litton Loan Servicing LP, et al., S.D.N.Y. Case No. 13-cv-00513 (ALC) ("Lyons"), whose terms will be finalized by December 12, 2015 and will become public shortly thereafter;

WHEREAS, this case is currently stayed against all Defendants other than Litton and American Modern — American Security Insurance Company, Ocwen Loan Servicing, LLC, Altisource Portfolio Solutions, S.A., and Beltline Road Insurance Agency, Inc., pending the resolution of settlement proceedings in Lee v. Ocwen Loan Servicing, LLC, et al., S.D. Fla. Case No. 14-cv-60649;

WHEREAS, Plaintiff and Defendants Litton and American Modern stipulate and agree that good cause exists to extend the deadline for Plaintiff to file the Second Amended Complaint to January 15, 2016, to allow Plaintiff to complete discovery as to SWBC, and assess the impact of American Modern's settlement in the Lyons action on this case and Plaintiff's potential amendments to the operative Complaint.

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED THAT, subject to the Court's approval, Plaintiff and Defendants Litton and American Modern agree to the following:

PURSUANT TO STIPULATION, IT IS SO ORDERED:

The deadline for Plaintiff to file and serve the Second Amended Complaint shall be extended to January 15, 2016.