STIPULATION TO EXTEND TIME FOR DEFENDANT WELLS FARGO BANK, N.A. TO RESPOND TO FIRST AMENDED COMPLAINT AND [PROPOSED] ORDER

RICHARD SEEBORG, District Judge.

Plaintiff DAVID STRONG ("Plaintiff") and defendant WELLS FARGO BANK, N.A., ("Defendant"), hereby stipulate as follows:

RECITALS

1. Plaintiff filed this action against Defendant on January 31, 2017 and served Defendant on February 2, 2017.

2. Defendant's initial deadline to respond to the Complaint was February 23, 2017

3. Plaintiff and Defendant agreed to extend the time for Defendant to respond to the Complaint up to and including March 27, 2017, so that Defendant could have additional time to investigate this matter and the parties may explore the possibility of settlement.

4. On or about March 15, 2017, Plaintiff informed Defendant that he intended to file a First Amended Complaint in the Action no later than April 7, 2017. Accordingly, Plaintiff and Defendant agreed that Defendant's deadline to respond to the complaint should be further extended to, April 28, 2017, which was 21 days from the anticipated date of Plaintiff filing an amended complaint.

5. Plaintiff did not file an amended Complaint by April 7, 2017, but indicated his intention to do so in the near future. Accordingly, the parties agreed to extend Defendant's response deadline to May 26, 2017.

6. Plaintiff filed the First Amended Complaint on April 28, 2017. Plaintiff and Defendant stipulated to extend the response deadline to June 26, 2017.

7. Based on the allegations in the First Amended Complaint and informal discovery, Plaintiff and Defendant are exploring settlement and stipulate that Defendant's deadline to respond to the First Amended Complaint shall be extended by another 30 days, up to and including July 26, 2017.

8. This change in deadline will not alter the date of any event or any deadline already fixed by Court order, local rules, or the Federal Rules of Civil Procedure.

THEREFORE, the parties stipulate as follows:

STIPULATION

1. The deadline for Defendant to respond to the anticipated First Amended Complaint or, in the event no amended complaint is filed, the initial complaint, shall be up to and including July 26, 2017.

2. This change in deadline will not alter the date of any event or any deadline already fixed by Court order, local rules, or the Federal Rules of Civil Procedure.

IT IS SO STIPULATED.

Pursuant to Local Rule 5-1(i)(3), I — Alisa A. Givental — attest that concurrence in the filing of this document has been obtained from Elliot W. Gale. /s/Alisa A. Givental

[PROPOSED] ORDER

Pursuant to the stipulation of the parties and good cause appearing, Wells Fargo Bank, N.A.'s deadline to respond to the anticipated First Amended Complaint or, in the event no amended complaint is filed, the initial complaint, shall be up to and including July 26, 2017. No other deadlines shall be affected by this Order.

IT IS SO ORDERED.