Opinion
Case No. 4:11-CV-02491-SBA
10-31-2011
RODOLFO VELASQUEZ, Plaintiff, v. BANK OF AMERICA N.A., LTD FINANCIAL SERVICES, L.P., Defendants.
By: Rodolfo Velasquez BRYAN CAVE LLP By:Jessica T. Ehsanian Attorneys for Defendant Bank of America, N.A.
Hon. Saundra Brown Armstrong Presiding
STIPULATION AND [PROPOSED] ORDER TO GIVE PLAINTIFF
LEAVE TO AMEND TO FILE A FIRST AMENDED COMPLAINT
Plaintiff RODOLFO VELASQUEZ and Defendant BANK OF AMERICA, N.A. hereby stipulate that:
WHEREAS, this action was originally filed on May 23, 2011,
WHEREAS, Defendant BANK OF AMERICA, N.A. has filed a motion to dismiss the Complaint on Jun e 15, 2011;
WHEREAS, the parties have met and conferred about the issues raised in the aforementioned motion to dismiss;
WHEREAS, Plaintiff wishes to amend his complaint to add COUNTRYWIDE HOME LOANS, INC. as a Defendant, add four new causes of action for Quiet Title, Declaratory and Injunctive Relieve, Intentional Infliction of Emotional Distress, and Quasi Contract;
WHEREFORE, Plaintiff proposes to file his amended complaint within 21 days of the date of this ORDER; and
WHEREFORE, Defendant BANK OF AMERICA, N.A. shall have 21 days from the date the First Amended Complaint is filed to answer, move to dismiss, or otherwise respond to Plaintiff's First Amended Complaint.
PLAINTIFF, IN PRO PER
By: Rodolfo Velasquez
BRYAN CAVE LLP
By:Jessica T. Ehsanian
Attorneys for Defendant Bank of America,
N.A.
ORDER
Based on the stipulation of the parties and good cause showing, IT IS HEREBY ORDERED that Plaintiff may file a First Amended Complaint with the changes detailed above within 21 days of the date of this ORDER. Defendants shall file a responsive pleading within 21 days of the filing of the First Amended Complaint.
IT IS SO ORDERED.
Hon. Saundra B. Armstrong, District Court Judge
United States District Court
Northern District of California
UNITED STATES DISTRICT COURT
FOR THE
NORTHERN DISTRICT OF CALIFORNIA
RODOLFO VELASQUEZ, Plaintiff,
v.
BANK OF AMERICA et al, Defendant.
Case Number: CV11-02491 SBA
CERTIFICATE OF SERVICE
I, the undersigned, hereby certify that I am an employee in the Office of the Clerk, U.S. District Court, Northern District of California.
That on October 31, 2011, I SERVED a true and correct copy(ies) of the attached, by placing said copy(ies) in a postage paid envelope addressed to the person(s) hereinafter listed, by depositing said envelope in the U.S. Mail, or by placing said copy(ies) into an inter-office delivery receptacle located in the Clerk's office.
Rodolfo Velasquez
426 Idora Avenue
Vallejo, CA 94591
Richard W. Wieking, Clerk
CLARK, Deputy Clerk
By: LISA R