STIPULATION FOR EXTENSION OF STAY AND ORDER [PROPOSED]
DATE: December 13, 2010 TIME: 2:00 p.m.
CALIFORNIA, SAN JOAQUIN COUNTY,
COURTROOM: 5 APN: 021-042-16,
Plaintiff United States of America, and Claimants William Pearce, Kristin Burckard, and JP Morgan Chase Bank, N.A.,*fn1 ("Chase") by and through their respective counsel, hereby stipulate that a stay is necessary in the above-entitled actions, and request that the Court enter an order staying all further proceedings for an additional 30 days.
JP Morgan Chase Bank, N.A., acquired certain assets and liabilities of claimant Washington Mutual Bank from the FDIC acting as a receiver.
Plaintiff has asked claimant Chase to provide plaintiff with a current appraisal and loan balance so plaintiff can calculate the equity remaining in the property. That information has not yet been provided. Counsel for Chase represents that Chase should be able to provide the information within the next 30 days so the plaintiff can make an informed decision about whether to continue with this litigation or to dismiss.
For this reason, the parties request that the status conference currently scheduled for December 13, 2010, be vacated and rescheduled to sometime in late January 2011.
Dated: December 6, 2010 BENJAMIN B. WAGNER United States Attorney By /s/ Kristin S. Door KRISTIN S. DOOR Assistant U.S. Attorney Attorneys for Plaintiff United States of America
Dated: December 6, 2010
DANIEL J. BRODERICK
Federal Defender By /s/ Timothy Zindel
(As authorized on 12/06/10) TIMOTHY ZINDEL Assistant Federal Defender Attorney for claimant William Pearce Dated: December 6, 2010 /s/ Krista Hart
(As authorized on 12/06/10) KRISTA HART Attorney for claimant Kristin Burckard
Dated: December 6, 2010 /s/ Scott J. Stillman (As authorized on 12/06/10)
SCOTT J. STILMAN Attorney for claimant JP Morgan Chase Bank, N.A., an acquirer of certain assets and liabilities of Washington Mutual ...