Free Stipulation - District Court of California - California

Case 3:07-cv-02568-MHP

Document 16

Filed 07/11/2007

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JOHN F. CAVIN, ESQ. (SB# 88946) HELEN V. POWERS, ESQ. (SB# 175164) BARDELLINI, STRAW, CAVIN & BUPP, LLP 2000 Crow Canyon Place, Suite 330 San Ramon, California 94583 Telephone: (925) 277-3580 Facsimile: (925) 277-3591 [email protected] [email protected] Attorneys for Defendant GATEWAY TITLE COMPANY

IN THE UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION AUDREY MCNAMARA NEVIS, ) ) Plaintiff, ) ) v. ) ) WELLS FARGO BANK, a California ) corporation, EXECUTIVE FINANCIAL ) LENDING, JOHN B. SPEAR, an individual, ) SHAI MOSHE, an individual, GATEWAY ) TITLE COMPANY, QUALITY LOAN ) SERVICES, Trustee and DOES 1-100, ) inclusive, ) ) Defendants. ) _____________________________________ ) Case No. C 07 2568 STIPULATION BY PLAINTIFF AND DEFENDANT GATEWAY TITLE COMPANY FOR EXTENSION OF TIME TO ANSWER COMPLAINT

Plaintiff AUDREY MCNAMARA NEVIS and Defendant GATEWAY TITLE COMPANY, by and through their attorneys of record, hereby agree and stipulate that Gateway Title Company shall have until and including July 16, 2007 to answer or otherwise respond to Plaintiff's complaint. Dated July 11, 2007 BARDELLINI, STRAW & CAVIN, LLP By: /s/ Helen V. Powers _______________________________ John F. Cavin Helen V. Powers Attorneys for Defendant Gateway Title Company Dated July 11, 2007 LAW OFFICES OF ROBERT KANE By: /s/ Robert Kane _______________________________ Robert Kane Attorney for Plaintiff Audrey McNamara Nevis

1 STIPULATION BY PLAINTIFF AND DEFENDANT GATEW AY TITLE COM PANY FOR EXTENSION OF TIM E TO ANSW ER COM PLAINT Case No. C 07 2568

Case 3:07-cv-02568-MHP

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Filed 07/11/2007

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PROOF OF SERVICE
I declare that I am employed in San Ramon, California. I am over the age of 18 years and not a party to this action. My business address is 2000 Crow Canyon Place, Suite 330, San Ramon, CA 94583. On this date, with this Proof of Service, I caused to be served the attached document(s) entitled: U.S. Dist. Court, Northern Div., Case No. C07-2568: Stipulation by Plaintiff and Defendant Gateway Title Company for Extension of Time to Answer Complaint on the following party(ies), as listed below: Attorneys for Plaintiff Audrey McNamara Nevis Paul B. Cohen, Esq. Brooke E. Thatcher, Esq. Legal Aid of Marin 30 North San Pedro Rd., Ste. 220 San Rafael, CA 94903 Tele: (415) 492-0230 Fax: (415) 492-0947 Attorneys for Plaintiff Audrey McNamara Nevis Shirley Hochhausen, Esq. Community Legal Services East Palo Alto 2117-B University Avenue East Palo Alto, CA 94303 Tele: (650) 326-6440 Fax: (650) 326-9722 The following is the procedure in which service of this document(s) was effected: _xx_ By Mail: I caused such envelope to be deposited in the mail at San Ramon, California with postage thereon fully prepaid in the designated area for outgoing mail in accordance with this office's practice, whereby mail is deposited in a U.S. mailbox in Contra Costa County at the close of the business day. By Fax: I caused a copy of the above named documents to be transmitted via facsimile to the facsimile number of the offices of the addressee(s) as indicated above. The facsimile machine used complied with California Rule of Court §2003, and no error was reported by the facsimile machine. Attorneys for Plaintiff Audrey McNamara Nevis Robert F. Kane, Esq. Law Offices of Robert F. Kane 870 Market Street San Francisco, CA 94102 Tele: (415) 982-1510 Fax: (415) 982-5821 email: [email protected]

I hereby declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on July 11, 2007 in San Ramon, California.

/s/ Cheryl J. McAlice Cheryl J. McAlice

2 STIPULATION BY PLAINTIFF AND DEFENDANT GATEW AY TITLE COM PANY FOR EXTENSION OF TIM E TO ANSW ER COM PLAINT Case No. C 07 2568