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Bruce C Williams BCW Consulting
25N 14h, Street Suite 830
DEC 7
2 2018
San Jose, CA 95112
408 702-7914
Bcw0905@gmail. com
COURT OF CALIFORNIA
MOMMWW
SUPERIOR COUNTgUF SANTA CLARA
R' A
QM
191 N. FIRST STREET. SAN JOSE, CA. 951 13
BRUCE C. WILLIAMS, Case No.2 l8cv328516
Plaintiff,
VS.
BAYVIEW SERVICEING, LOAN LLC, REQUEST FOR EXTENSION
FIDELITY NATIONAL TITLE AND 1Ns., REzDEFENDANTS EX PARTE
INTERBAY FUNDING, DIVERSIFIED APPLICATIONF RDISMISSAL.
INVESTMENT SERVICE, BAYVIEW LOAN
SERVICING, LLC, AND DOES 1-50,
Defendant
1, Bruce Williams, Plaintiff in this case, respectfully request extension of time to file Plaintiffs
amended complaint. The above-referenced document will e filed on 12-27—2018. Good cause
exists for the requested extension. Today, (12-26-18) Plain ff received an email, from Kimberly A.
Bowers, Defendants “Litigation Paralegal”, and without phone call became aware of Defendants
Ex parte Application for a Dismissal ofEntire Action, in hich Plaintiff has been fighting to restore
Plaintiffs property rights. Plaintiffs inability t0 ha e consistent legal representation for the
completion of leave to amend order t0 the comp int, has contributed the delay in filing the
amended complaint. The Plaintiff further asks t e Court t0 allow the Plaintiff t0 amend the
Complaint to add new causes 0f action or to sup rsede the current causes 0f action with different
causes 0f action. This request should not be p judicial t0 Defendant in any degree. Plaintiff has
received N_O_ prior extensions. In sum, the efendant cannot establish that Defendant will be
irreparably prejudiced; therefore Court shou deny this emergency application. I now ask that the
Court grant me additional 30 days to file t amended Complaint. Also, Plaintifffurther request that
if the Court does not grant Plaintiff’s r uest for an extension, that it will make any ruling non-
prejudicial against Plaintiff with respec t0 new causes 0f action. where said causes 0f action are
still grounded in the protection 0f Plaintiff‘s interest in the title of his property. I declare under
- 1
.
REQUEST AND ORDER FOR EXTENSION TO FILE AMENDED COMPLAINT
penalty of perjury under the laws of the State 0f California that the foregoing is true and correct.
l\) Executed this 26th day of December 2018 at Santa Clara, California.
DATED: December 26, 201 8
BRUCE
PLAINTIFF
C.
Mm
WILLIAMS
SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA
191 N. FIRST STREET, SAN JOSE, CA. 951 13
BRUCE C. WILLIAMS, Case No.: 18cv328516
Plaintiff,
vs.
BAYVIEW SERVICEING, LOAN LLC. ORDER
FIDELITY NATIONAL TITLE AND INS..
INTERBAY FUNDING, DIVERSIFIED
INVESTMENT SERVICE, BAYVIEW LOAN
SERVICING. LLC, AND DOES 1-50,
Defendant
Having considered Plaintiffs’ Request,
IT IS HEREBY ORDERED that the Re est for Extension of Time is GRANTED. Plaintiff has
COMPLAINT.
days from the date 0fthis o er to file: PLAINTIFFS LEAVE
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TO AMENDED
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DATED: 7/ L7 Signed:
Hon. M7
Superior Court Judge
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REQUEST AND ORDER FOR EXTENSION TO FILE AMENDED COMPLAINT
SERVICE
10 ZIEVE. BRODNAX & STEELE, LLP
John C. Steele, Bar No. 179875
11 Samantha MacLeod, Bar No. 270770
30 Corporate Park, Suite 450
12
Irvine, CA 92606
13 Phone: (714) 848-7920
Fax: (714) 908—2615
14 Attorney for: BAYVIEW LOAN SERVICING, LLC
15
Mail to: kbowerngzbslawcom
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REQUEST AND ORDER FOR EXTENSION TO FILE AMENDED COMPLAINT
PROOF OF SERVICE
State 0f California )
) ss.
County of Santa Clara )
I am employed in the County of Santa Clara,
party to the within action.
On December, 26m 2018,
My
I
business
State of California.
addressmflQA/M [f
served the foregoing document described
Iam 0v
as:
r the
)fi
a
W
e of 18 and
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REQUEST AND ORDER FOR EXTENSION TO FILE LEAVE TO AMENDED COMPLAINT
SEE ATTACHED SERVICE LIST
[X] (BY FACSIMILE) The facsimile machine I used complied with Rule 2003(3) and no error
was reported by the machine. Pursuant to Rule 2008(e)(4), Icaused the machine t0 print a record of
the transaction.
[X] (BY MAIL, 1013a, 2015.5 C.C.P.)
[X] I deposited such envelope in the mail at Santa Clara, California. The envelope was mailed
with postage thereon fully prepaid.
[X] I am readily familiar with the firm’s practice for collection and processing correspondence
for mailing. Under that practice, this document will be deposited with the U.S. Postal Service on
this date with postage therefore fully prepaid at Santa Clara, California in the ordinary course 0f
business. I am aware that on motion of the party served, service is presumed invalid if postal
cancellation date or postage meter date is more than one day after date of deposit for mailing in
affidavit.
[ ] (BY PERSONAL SERVICE) I caused the foregoing envelope to be delivered by hand to
the addressee 0n the attached Service List.
[ ] (BY FEDERAL EXPRESS ) I caused the foregoing envelope t0 be delivered by xxxx
FEDEX
_4 -
REQUEST AND ORDER FOR EXTENSION TO FILE AMENDED COMPLAINT
[X] (STATE) I declare under penalty of perjury under the laws of th State of California that
the above is true and correct.
Name 0f Declarant
77mm WAWSKQ
\IO\
-5-
REQUEST AND ORDER FOR EXTENSION TO FILE AMENDED COMPLAINT
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Bruce C Williams BCW Consulting 25N 14h, Street Suite 830 DEC 7 2 2018 San Jose, CA 95112 408 702-7914 Bcw0905@gmail. com COURT OF CALIFORNIA MOMMWW SUPERIOR COUNTgUF SANTA CLARA R' A QM 191 N. FIRST STREET. SAN JOSE, CA. 951 13 BRUCE C. WILLIAMS, Case No.2 l8cv328516 Plaintiff, VS. BAYVIEW SERVICEING, LOAN LLC, REQUEST FOR EXTENSION FIDELITY NATIONAL TITLE AND 1Ns., REzDEFENDANTS EX PARTE INTERBAY FUNDING, DIVERSIFIED APPLICATIONF RDISMISSAL. INVESTMENT SERVICE, BAYVIEW LOAN SERVICING, LLC, AND DOES 1-50, Defendant 1, Bruce Williams, Plaintiff in this case, respectfully request extension of time to file Plaintiffs amended complaint. The above-referenced document will e filed on 12-27—2018. Good cause exists for the requested extension. Today, (12-26-18) Plain ff received an email, from Kimberly A. Bowers, Defendants “Litigation Paralegal”, and without phone call became aware of Defendants Ex parte Application for a Dismissal ofEntire Action, in hich Plaintiff has been fighting to restore Plaintiffs property rights. Plaintiffs inability t0 ha e consistent legal representation for the completion of leave to amend order t0 the comp int, has contributed the delay in filing the amended complaint. The Plaintiff further asks t e Court t0 allow the Plaintiff t0 amend the Complaint to add new causes 0f action or to sup rsede the current causes 0f action with different causes 0f action. This request should not be p judicial t0 Defendant in any degree. Plaintiff has received N_O_ prior extensions. In sum, the efendant cannot establish that Defendant will be irreparably prejudiced; therefore Court shou deny this emergency application. I now ask that the Court grant me additional 30 days to file t amended Complaint. Also, Plaintifffurther request that if the Court does not grant Plaintiff’s r uest for an extension, that it will make any ruling non- prejudicial against Plaintiff with respec t0 new causes 0f action. where said causes 0f action are still grounded in the protection 0f Plaintiff‘s interest in the title of his property. I declare under - 1 . REQUEST AND ORDER FOR EXTENSION TO FILE AMENDED COMPLAINT penalty of perjury under the laws of the State 0f California that the foregoing is true and correct. l\) Executed this 26th day of December 2018 at Santa Clara, California. DATED: December 26, 201 8 BRUCE PLAINTIFF C. Mm WILLIAMS SUPERIOR COURT OF CALIFORNIA COUNTY OF SANTA CLARA 191 N. FIRST STREET, SAN JOSE, CA. 951 13 BRUCE C. WILLIAMS, Case No.: 18cv328516 Plaintiff, vs. BAYVIEW SERVICEING, LOAN LLC. ORDER FIDELITY NATIONAL TITLE AND INS.. INTERBAY FUNDING, DIVERSIFIED INVESTMENT SERVICE, BAYVIEW LOAN SERVICING. LLC, AND DOES 1-50, Defendant Having considered Plaintiffs’ Request, IT IS HEREBY ORDERED that the Re est for Extension of Time is GRANTED. Plaintiff has COMPLAINT. days from the date 0fthis o er to file: PLAINTIFFS LEAVE V 6 TO AMENDED N 05 V °’ g- W n I fiJ‘d ‘I‘Q 0 fl‘ Q ” é . M H 4." ah “CU *0 Lu» wt— a .1. w, DATED: 7/ L7 Signed: Hon. M7 Superior Court Judge a- W -2- REQUEST AND ORDER FOR EXTENSION TO FILE AMENDED COMPLAINT SERVICE 10 ZIEVE. BRODNAX & STEELE, LLP John C. Steele, Bar No. 179875 11 Samantha MacLeod, Bar No. 270770 30 Corporate Park, Suite 450 12 Irvine, CA 92606 13 Phone: (714) 848-7920 Fax: (714) 908—2615 14 Attorney for: BAYVIEW LOAN SERVICING, LLC 15 Mail to: kbowerngzbslawcom 16 17 18 19 20 21 N [\J l\) b.) 25 26 27 28 q -3- REQUEST AND ORDER FOR EXTENSION TO FILE AMENDED COMPLAINT PROOF OF SERVICE State 0f California ) ) ss. County of Santa Clara ) I am employed in the County of Santa Clara, party to the within action. On December, 26m 2018, My I business State of California. addressmflQA/M [f served the foregoing document described Iam 0v as: r the )fi a W e of 18 and / t 204? a 4L) ‘ REQUEST AND ORDER FOR EXTENSION TO FILE LEAVE TO AMENDED COMPLAINT SEE ATTACHED SERVICE LIST [X] (BY FACSIMILE) The facsimile machine I used complied with Rule 2003(3) and no error was reported by the machine. Pursuant to Rule 2008(e)(4), Icaused the machine t0 print a record of the transaction. [X] (BY MAIL, 1013a, 2015.5 C.C.P.) [X] I deposited such envelope in the mail at Santa Clara, California. The envelope was mailed with postage thereon fully prepaid. [X] I am readily familiar with the firm’s practice for collection and processing correspondence for mailing. Under that practice, this document will be deposited with the U.S. Postal Service on this date with postage therefore fully prepaid at Santa Clara, California in the ordinary course 0f business. I am aware that on motion of the party served, service is presumed invalid if postal cancellation date or postage meter date is more than one day after date of deposit for mailing in affidavit. [ ] (BY PERSONAL SERVICE) I caused the foregoing envelope to be delivered by hand to the addressee 0n the attached Service List. [ ] (BY FEDERAL EXPRESS ) I caused the foregoing envelope t0 be delivered by xxxx FEDEX _4 - REQUEST AND ORDER FOR EXTENSION TO FILE AMENDED COMPLAINT [X] (STATE) I declare under penalty of perjury under the laws of th State of California that the above is true and correct. Name 0f Declarant 77mm WAWSKQ \IO\ -5- REQUEST AND ORDER FOR EXTENSION TO FILE AMENDED COMPLAINT