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ELECTRONICALLY FILED
COURT OF COMMON PLEAS
Tuesday, March 09, 2010 5:18:19 PM
CASE NUMBER: 2007 CV 09571 Docket ID: 14865190
GREGORY A BRUSH
CLERK OF COURTS MONTGOMERY COUNTY OHIO
COURT OF COMMON PLEAS
MONTGOMERY COUNTY, OHIO
U.S. Bank, N.A., as Trustee for the Structured Case No. 2007 CV 9571
Asset Securities Corporation Mortgage Loan
Trust, 2006- NC1, Judge Connie S. Price
Plaintiff,
PLAINTIFF’S MOTION TO CONTINUE
-vs- HEARING SCHEDULED
FOR MARCH 22, 2010 AT
Wesley A. Quinn, et al., 10:30 A.M.
Defendants.
Comes now counsel for Plaintiff, U.S. Bank, N.A., as Trustee for the Structured
Asset Securities Corporation Mortgage Loan Trust, 2006- NC1, and hereby
respectfully moves this Court for an Order to Continue the Hearing scheduled in this
action for March 22, at 10:30 a.m. Plaintiff’s counsel, Attorney Deanna C.
Stoutenborough, has been designated Trial Counsel and will be appearing as such in
a three-day Jury Trial before the Honorable Magistrate Anthony Cornicelli of the
Court of Common Pleas of Trumbull County, Ohio in Case No. 2008 CV 621. Said
Jury Trial is set to begin Monday, March 22, 2010 and continue through March 24,
2010.
Co-counsel for Plaintiff herein, Attorney Rick DeBlasis, is also Trial Counsel in
Trumbull County Case No. 2008 CV 621. As such, Attorney DeBlasis, likewise, has a
LSR # 200725626
conflict with the March 22, 2010 hearing date in this action. Based upon the
foregoing, cousnel for Plaintiff herein respectfully request this honorable continue
the hearing set for this matter on March 22, 2010 to a later date. This Motion to
Continue Hearing is not being interposed for purposes of delay and no other party
will be prejudiced by the continuance requested.
A proposed Order Granting Plaintiff’s Motion to Continue Hearing is being
provided with this Motion.
Respectfully submitted,
/S/ Deanna C. Stoutenborough
Deanna C. Stoutenborough (# 0069761)
Rick D. DeBlasis, Esq. (# 0012992)
Craig A. Thomas, Esq. (#0037667)
LERNER, SAMPSON & ROTHFUSS
Attorney for Plaintiff
120 E. Fourth St., 8th Floor
Cincinnati, OH 45202
Ph.: (513) 412-6093
Fx.: (513) 362-3592
Deanna.stoutenborough@lsrlaw.com
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CERTIFICATE OF SERVICE
I hereby certify that, on March 9, 2010, I electronically filed the foregoing
Motion to Continue Hearing Scheduled for March 22, 2010 at 10:30 a.m. with the Clerk of
the Court using the electronic filing system and have requested the Clerk to send
notification of such filing, via the ECF system, to the following:
Craig A. Thomas, Esq.
P.O. Box 5480
Cincinnati, OH 45201
Co-counsel for Plaintiff
Randall J. Smith, Esq.
Miami Valley Fair Housing Center, Inc.
21-23 E. Babbitt Street
Dayton, OH 45405
Counsel for Defendants, Wesley and Marion Quinn
Collette S. Carr, Esq.
301 West Third Street
5th Floor
Dayton, OH 45402
Counsel for Defendant, Montgomery County Treasurer
I hereby further certify that a true and correct copy of the foregoing Motion to
Continue Hearing Scheduled for March 22, 2010 at 10:30 a.m. was sent via ordinary U.S.
mail, postage prepaid, to the following on this 9th day of March, 2010:
Chase Home Finance
3415 Vision Drive
Columbus, OH 43219
/S/ Deanna C. Stoutenborough
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ELECTRONICALLY FILED COURT OF COMMON PLEAS Tuesday, March 09, 2010 5:18:19 PM CASE NUMBER: 2007 CV 09571 Docket ID: 14865190 GREGORY A BRUSH CLERK OF COURTS MONTGOMERY COUNTY OHIO COURT OF COMMON PLEAS MONTGOMERY COUNTY, OHIO U.S. Bank, N.A., as Trustee for the Structured Case No. 2007 CV 9571 Asset Securities Corporation Mortgage Loan Trust, 2006- NC1, Judge Connie S. Price Plaintiff, PLAINTIFF’S MOTION TO CONTINUE -vs- HEARING SCHEDULED FOR MARCH 22, 2010 AT Wesley A. Quinn, et al., 10:30 A.M. Defendants. Comes now counsel for Plaintiff, U.S. Bank, N.A., as Trustee for the Structured Asset Securities Corporation Mortgage Loan Trust, 2006- NC1, and hereby respectfully moves this Court for an Order to Continue the Hearing scheduled in this action for March 22, at 10:30 a.m. Plaintiff’s counsel, Attorney Deanna C. Stoutenborough, has been designated Trial Counsel and will be appearing as such in a three-day Jury Trial before the Honorable Magistrate Anthony Cornicelli of the Court of Common Pleas of Trumbull County, Ohio in Case No. 2008 CV 621. Said Jury Trial is set to begin Monday, March 22, 2010 and continue through March 24, 2010. Co-counsel for Plaintiff herein, Attorney Rick DeBlasis, is also Trial Counsel in Trumbull County Case No. 2008 CV 621. As such, Attorney DeBlasis, likewise, has a LSR # 200725626 conflict with the March 22, 2010 hearing date in this action. Based upon the foregoing, cousnel for Plaintiff herein respectfully request this honorable continue the hearing set for this matter on March 22, 2010 to a later date. This Motion to Continue Hearing is not being interposed for purposes of delay and no other party will be prejudiced by the continuance requested. A proposed Order Granting Plaintiff’s Motion to Continue Hearing is being provided with this Motion. Respectfully submitted, /S/ Deanna C. Stoutenborough Deanna C. Stoutenborough (# 0069761) Rick D. DeBlasis, Esq. (# 0012992) Craig A. Thomas, Esq. (#0037667) LERNER, SAMPSON & ROTHFUSS Attorney for Plaintiff 120 E. Fourth St., 8th Floor Cincinnati, OH 45202 Ph.: (513) 412-6093 Fx.: (513) 362-3592 Deanna.stoutenborough@lsrlaw.com 2 CERTIFICATE OF SERVICE I hereby certify that, on March 9, 2010, I electronically filed the foregoing Motion to Continue Hearing Scheduled for March 22, 2010 at 10:30 a.m. with the Clerk of the Court using the electronic filing system and have requested the Clerk to send notification of such filing, via the ECF system, to the following: Craig A. Thomas, Esq. P.O. Box 5480 Cincinnati, OH 45201 Co-counsel for Plaintiff Randall J. Smith, Esq. Miami Valley Fair Housing Center, Inc. 21-23 E. Babbitt Street Dayton, OH 45405 Counsel for Defendants, Wesley and Marion Quinn Collette S. Carr, Esq. 301 West Third Street 5th Floor Dayton, OH 45402 Counsel for Defendant, Montgomery County Treasurer I hereby further certify that a true and correct copy of the foregoing Motion to Continue Hearing Scheduled for March 22, 2010 at 10:30 a.m. was sent via ordinary U.S. mail, postage prepaid, to the following on this 9th day of March, 2010: Chase Home Finance 3415 Vision Drive Columbus, OH 43219 /S/ Deanna C. Stoutenborough 3