Opinion
MORGAN, LEWIS & BOCKIUS LLP, Amy M. Spicer, San Francisco, CA.
MORGAN, LEWIS & BOCKIUS LLP, Joseph Duffy, Los Angeles, CA, Attorneys for Defendant JPMORGAN CHASE BANK, N.A.
FRANZ LAW, Pamela M. Schuur, Attorneys for Plaintiff VLADIMIR RIVKIN.
STIPULATION TO EXTEND TIME FOR DEFENDANT JPMORGAN CHASE BANK, N.A. TO RESPOND TO PLAINTIFF'S FIRST 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.) JPMC's current deadline to respond to the First Amended Complaint is February 19, 2015.
G. As of February 17, 2015, the Court has not yet ruled on Plaintiff's request for leave to file the second amended complaint.
H. In view of Plaintiff's pending request for leave to amend the operative complaint, the Parties have agreed to extend the time for JPMC to respond to Plaintiff's First Amended Complaint to and including March 25, 2015.
I. This is the Parties' third request for an extension of time to respond to the First Amended Complaint.
IT IS THEREFOR STIPULATED that JPMC shall have to and including March 25, 2015 to respond to Plaintiff's First Amended Complaint.
ORDER
IT IS SO ORDERED.