Page 1 - APPELLEES BANK OF NEW YORK MELLON AND SELECT PORTFOLIO 

SERVICING, INC.’S RESPONSE TO APPELLANT’S REQUEST TO EXTEND 

TIME TO FILE BRIEF 

88443271.1 0052161-03258 

Oren B. Haker, OSB No. 130162 

oren.haker@stoel.com 

Crystal S. Chase, OSB No. 093104 

crystal.chase@stoel.com 

STOEL RIVES LLP

760 SW Ninth Avenue 

Suite 3000 

Telephone: (503) 224-3380 

Facsimile: (503) 220-2480 

Attorneys for Appellees Bank of New York Mellon and Select Portfolio 

Servicing, Inc. 

UNITED STATES DISTRICT COURT 

DISTRICT OF OREGON 

EUGENE DIVISION 

LORI DIANE BACZKOWSKI, 

Appellant, 

v. 

BANK OF NEW YORK MELLON; 

QUALITY LOAN SERVICE 

CORPORATION OF WASHINGTON; and 

SELECT PORTFOLIO SERVICING, INC., 

Appellees. 

Case No.: 6:16-cv-00150-MC 

APPELLEES BANK OF NEW YORK 

MELLON AND SELECT PORTFOLIO 

SERVICING, INC.’S RESPONSE TO 

APPELLANT’S REQUEST TO EXTEND 

TIME TO FILE BRIEF 

Appellees Bank of New York Mellon, f/k/a The Bank of New York, as Trustee, on 

Behalf of the Holders of the Alternative Loan Trust 2007-23cb, Mortgage Pass-Through 

Certificates, Series 2007-23cb (“the Trust”) and Select Portfolio Servicing, Inc. (“SPS”) hereby 

Case 6:16-cv-00150-MC Document 22 Filed 09/29/16 Page 1 of 3
Page 2 - APPELLEES BANK OF NEW YORK MELLON AND SELECT PORTFOLIO 

SERVICING, INC.’S RESPONSE TO APPELLANT’S REQUEST TO EXTEND 

TIME TO FILE BRIEF 

88443271.1 0052161-03258 

oppose pro se Appellant Lori Diane Baczkowski’s (“Debtor” or “Appellant”) Request to 

Extend Time to File Brief - FRBP 8011 (“Request to Extend Time”). 

Debtor filed her Notice of Appeal from the order of the United States Bankruptcy Court 

for the District of Oregon dismissing her adversary proceeding on January 26, 2016 (Dkt. #1). 

The Court ordered her to serve and file her opening brief within 30 days but Debtor did not do 

so. (Dkt. #10.) The Court issued an order to Debtor to show cause why the appeal should not be 

dismissed and, specifically, to file her opening brief by June 13, 2016. (Dkt. #10.) Following 

filing of the opening brief, the Trust and SPS timely filed the answering brief on July 13, 2016. 

(Dkt. #13.) On July 27, 2016, Debtor filed a request for an extension of time to file her reply 

brief until September 26, 2016, and the Court granted that request. (Dkt. #20.) Debtor has now 

filed a second Request to Extend Time to file her brief to October 24, 2016. (Dkt. #21.) That 

Request to Extend Time is substantively identical to the prior request for an extension of time 

and does not identify any particular reason why additional time is needed beyond the extension 

of time already received by Debtor. (Id.) 

Nine months will have elapsed by Debtor’s proposed deadline of October 24, 2016. The 

Trust and SPS respectfully request that, to avoid further delay in resolution of this bankruptcy 

appeal, if the Court is inclined to grant Debtor’s Request to Extend Time, the Court also order 

that no further extensions beyond October 24, 2016 will be granted. 

DATED: September 29, 2016. STOEL RIVES LLP

/s/ Crystal S. Chase 

OREN B. HAKER, OSB No. 130162 

CRYSTAL S. CHASE, OSB No. 093104 

Telephone: (503) 224-3380 

Attorneys for Appellees the Trust and Select 

Portfolio Servicing, Inc. 

Case 6:16-cv-00150-MC Document 22 Filed 09/29/16 Page 2 of 3
Page 1 - CERTIFICATE OF SERVICE 

CERTIFICATE OF SERVICE 

I hereby certify that I served the foregoing APPELLEES BANK OF NEW YORK 

MELLON AND SELECT PORTFOLIO SERVICING, INC.’S RESPONSE TO APPELLANT’S 

REQUEST TO EXTEND TIME TO FILE BRIEF on the following named person(s) on the date 

indicated below by 

 mailing with postage prepaid 

 hand delivery 

 facsimile transmission 

 overnight delivery 

 email 

 notice of electronic filing using the Cm/ECF system 

to said person(s) a true copy thereof, contained in a sealed envelope, addressed to said person(s) 

at his or her last-known address(es) indicated below. 

Lori Diane Bacskowski 

1025 Ne Fall Drive 

Grants Pass, OR 97526 

Appellant, Pro Se 

DATED: September 29, 2016. 

STOEL RIVES LLP

/s/ Crystal S. Chase 

OREN B. HAKER, OSB No. 130162 

CRYSTAL S. CHASE, OSB No. 093104 

Telephone: (503) 224-3380 

Attorneys for Appellees the Trust and Select 

Portfolio Servicing, Inc. 

Case 6:16-cv-00150-MC Document 22 Filed 09/29/16 Page 3 of 3