Stephen C. Ruehmann (167533), Robin D. Shofner (272552), RUEHMANN LAW FIRM, P.C., Folsom, CA, Attorneys for Plaintiff NIKOS GLIMIDAKAS.
Julie A. Kole (203681), KEESAL, YOUNG, & LOGAN, Helen D. Hsueh (264745), A Professional Corporation, San Francisco, CA, Attorneys for Defendants JPMORGAN CHASE BANK, N.A. (erroneously sued herein as JP MORGAN CHASE BANK, N.A., as successor by merger to CHASE HOME FINANCE, L.L.C) and U.S. BANK, N.A.
JOINT STIPULATION FOR STAY OF PROCEEDINGS; [PROPOSED] ORDER
SAMUEL CONTI, District Judge.
Plaintiff NIKOS GLIMIDAKAS ("Plaintiff") and Defendants JPMORGAN CHASE BANK, N.A., (erroneously sued as JPMorgan Chase Bank, N.A., as successor by merger to Chase Home Finance, L.L.C) and U.S. BANK, N.A. (collectively, "Defendant"), (collectively "Parties") by and through their counsel of record, hereby stipulate and requests as follows:
1. Plaintiff filed his Complaint on May 1, 2013, in San Francisco County Superior Court, Case No. CGC-13-531068;
2. The underlying issue of this action is the potential foreclosure of the subject property located at 15 Duboce Avenue, San Francisco, California 94103;
3. On June 3, 2013, Defendants filed a Notice of Removal of Action with the United States District Court, Northern District of California (San Francisco Division) and the above-mentioned case was assigned Case No. 3:13-cv-02484-SC;
4. WHEREAS, Defendants timely filed a Motion to Dismiss Plaintiff's Complaint on June 10, 2013 in the above-entitled Court ("Motion to Dismiss");
5. WHEREAS, Plaintiff's response to Defendants' Motion to Dismiss must Curently be filed on or before June 24, 2013;
6. WHEREAS, Defendants' reply to Plaintiff's response to Defendants' Motion to Dismiss must currently be filed on or before July 1, 2013;
7. WHEREAS, the hearing on Defendants' motion to Dismiss is currently set for July 26, 2013 at 10:00 a.m. in Courtroom 1, 17th Floor, before Hon. Samuel Conti;
8. WHEREAS, the Parties are currently engaged in settlement negotiations and continue to engage in ...