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Joseph O. Oiyemhonlan, An Individual and v. Jp Morgan Mortgage Acquisition Corp.

January 23, 2012

JOSEPH O. OIYEMHONLAN, AN INDIVIDUAL AND
MARTHA OIYEMHONLAN, AN INDIVIDUAL,
PLAINTIFFS,
v.
JP MORGAN MORTGAGE ACQUISITION CORP., BUSINESS ENTITY UNKNOWN;
QUALITY LOAN SERVICE CORP., BUSINESS ENTITY UNKNOWN; AND DOES 1 THROUGH 100,
DEFENDANTS.



The opinion of the court was delivered by: Judge: Magistrate Elizabeth D. LaPorte

BRYAN CAVE LLP C. Scott Greene, California Bar No. 277445 2 Yvonne P. Greer, California Bar No. 214072 Two Embarcadero Center, Suite 1410 3 San Francisco, CA 94111-3907 Telephone: (415) 675-3400 4 Facsimile: (415) 675-3434 Email: scott.greene@bryancave.com 5 greery@bryancave.com BRYAN CAVE LLP Sean D. Muntz, California Bar No. 223549 3161 Michelson Drive, Suite 1500 8 Irvine, California 92612-4414 Telephone: (949) 223-7000 9 Facsimile: (949) 223-7100 Email: sean.muntz@bryancave.com 10 Attorneys for Defendants JPMORGAN CHASE BANK, N.A. (erroneously named as Chase Bank); and QUALITY LOAN 12 13 7 SERVICE CORP., INC. Bryan Cave LLP Embarcadero Center, Suite 1410 San Francisco, CA 94111

Date Action Filed: November 18, 2011

JOINT STIPULATION TO STAY PROCEEDINGS FOR SIXTY DAYS AND [PROPOSED] ORDER AS MODIFIED

Date Action Removed: December 22, 2011

STIPULATION

Plaintiffs Joseph and Martha Oiyemhonlan ("Plaintiffs") and Defendants JP MORGAN CHASE BANK, N.A, ("Chase") and QUALITY LOAN SERVICE CORP., INC. (collectively 4 "Defendants") by and through their respective counsel, STIPULATE and AGREE as follows: 5 WHEREAS Plaintiffs filed a complaint in the Superior Court of the County of Alameda 6 on November 18, 2011;

WHEREAS, on November 22, 2011 in the Superior Court of the County of Alameda, Plaintiffs obtained an ex parte temporary restraining order ("TRO") enjoining the Trustee's sale of 9 the real property at 27535 Orlando Avenue in Hayward, California (the "Property"); 10

WHEREAS Defendants removed the action to this Court pursuant to the provisions of 28 U.S.C.section 1441(b) on December 22, 2011;

WHEREAS Defendants filed a Motion to Dismiss Plaintiffs' Complaint on December 29, 2011;

WHEREAS Defendants' reply in response to any opposition to Defendants' Motion to Dismiss is due on January 19, 2011; 16

WHEREAS the hearing on Defendants' Motion to Dismiss is set for February 14, 2012;

WHEREAS the Case Management Conference is presently scheduled for April 3, 2012.

WHEREAS the parties wish to stay all proceedings in this matter until March 19, 2012, including hearings, briefings, appearances and any other deadlines imposed by law or the Court, 20 pending a determination by Defendant Chase of Plaintiffs' suitability for loan modification, which 21 is economically and judicially efficient; 22

WHEREAS the parties stipulate and agree that Plaintiffs' time to file an Opposition to Defendants' Motion to Dismiss ...


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