STIPULATION AND ORDER EXTENDING DEFENDANTS' TIME TO RESPOND TO THE AMENDED COMPLAINT AND MODIFYING BRIEFING SCHEDULE

DUNCAN W. KEIR, Bankruptcy Judge.

WHEREAS, on April 29, 2011, plaintiffs Joel I. Sher, Chapter 11 Trustee, and Zuni Investors, LLC (together, "Plaintiffs") filed a Complaint, captioned Joel I. Sher, et ano. v. Countrywide Home Loans Inc., et ano., Adversary Proceeding No. 11-00337, pending in the United States Bankruptcy Court for the District of Maryland, Baltimore Division;

WHEREAS, on July 8, 2011, defendant Countrywide Home Loans, Inc. ("Countrywide") and defendant Bank of America Corporation (collectively, "Defendants") filed motions to dismiss the Complaint;

WHEREAS, on July 9, 2011, Countrywide filed a motion to transfer venue of this adversary proceeding to the United States District Court for the Central District of California (the "Venue Motion");

WHEREAS, on July 9, 2011, Defendants filed a motion to withdraw the reference of the Plaintiffs' Complaint (the "Motion to Withdraw the Reference");

WHEREAS, on July 29, 2011, Plaintiffs filed an Amended Complaint for Breach of Contract (the "Amended Complaint"), which, by superseding the Complaint, rendered Defendants' motions to dismiss the Complaint moot;

WHEREAS, the date by which the Defendants are required to move, answer, or otherwise respond to the Amended Complaint is August 12, 2011;

WHEREAS, the parties have agreed that Defendants' time to move, answer, or otherwise respond to the Amended Complaint should be extended to September 2, 2011;

WHEREAS, the parties have agreed that Plaintiffs should have until September 23, 2011 to respond to Defendants' motions to dismiss, should Defendants so move;

WHEREAS, the parties have agreed that Defendants should have until October 7, 2011 to reply to Plaintiffs' oppositions to Defendants' motion(s) to dismiss;

WHEREAS, the Defendants have not yet determined whether they will stand on the Venue Motion and the Motion to Withdraw the Reference as previously filed or will instead file a new Venue Motion and a new Motion to Withdraw the Reference;

WHEREAS, the parties have agreed that Defendants should have until September 2, 2011 either to file a new Venue Motion and a new Motion to Withdraw the Reference or to advise the Plaintiffs that Defendants will stand on those motions as filed on July 9, 2011;

WHEREAS, the parties have agreed that Plaintiffs should have until September 23, 2011 to respond to the Venue Motion and the Motion to Withdraw the Reference;

WHEREAS, the parties have agreed that Defendants should have until October 7, 2011 to reply to Plaintiffs' responses to the Venue Motion and the Motion to Withdraw the Reference;

WHEREAS, each party has reserved all rights with respect to additional extensions of Defendants' time to move, answer or otherwise respond to the Amended Complaint, including (without limitation) the parties' rights both to request additional extensions from the Court and to oppose such requests; and

IT IS HEREBY STIPULATED AND AGREED, by the undersigned parties, by and through their attorneys1, that the time for Defendants Countrywide Home Loans, Inc. and Bank of America Corporation to move, answer, or otherwise respond to the Amended Complaint is hereby extended through and including September 2, 2011; that Plaintiffs Chapter 11 Trustee and Zuni Investors, LLC shall have until September 23, 2011 to oppose Defendants' motions, should Defendants so move; and that Defendants shall have until October 7, 2011 to reply to Plaintiffs' oppositions to Defendants' motions; and

IT IS HEREBY FURTHER STIPULATED AND AGREED, that Defendants shall have until September 2, 2011 either (1) to inform Plaintiffs of their intention to stand on Defendants' previously-filed Motion to Transfer Venue and Motion to Withdraw the Reference; or (2) to file a new Motion to Transfer Venue and a new Motion to Withdraw the Reference; that Plaintiffs shall have until September 23, 2011 to respond to Defendants' Motion to Transfer Venue and Motion to Withdraw the Reference; and that Defendants shall have until October 7, 2011 to reply to Plaintiffs' responses to Defendants' Motion to Transfer Venue and Motion to Withdraw the Reference.

CERTIFICATE PURSUANT TO EXHIBIT A TO ADMINISTRATION ORDER NO. 03-02

I HEREBY CERTIFY that the terms of the copy of the Consent Order submitted to the Court are identical to those set forth in the original Consent Order; and the signatures represented by the /s/ on this copy reference the signatures of the consenting parties on the original Consent Order.