DEFTS' RESPONSE TO PLTF'S MEMORANDUM CONTRA FILED Attorney: LOMBARDO, VINCENT T (0000790)

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vite ‘COMMON PLEAS COURT OF MONTGOMERY COUNTY, OHIO

  

 

CIVIL DIVISION
U.S. Bank N.A. as Trustee, CASE NO. 2007-CV-9571
Plaintiff JUDGE Jeffrey E. Froelich

-v-

MOTION FOR IMMEDIATE STAY OF
FORECLOSURE AND ORDER FOR

Wesley A. Quinn, et al,
SALE

Defendants.

 

Now comes Defendants Wesley Quinn and Marion Quinn (Quinns), by and through their
legal Counsel, who respectfully request that this Court grant an immediate stay on the
enforcement and/or execution of its Decree of Foreclosure signed on February 11, 2008, and
Order for Sale, signed on March 1, 2008. A Sheriff's sale has been set for February 27, 2009 at
10:00 and this sale should not be allowed to proceed until the Quinns’ Motion for Relief from the
Default Judgment entered against them in this case has been fully considered.

The Quinns filed their 60(b) motion for relief on December 18, 2008.

If a stay is not granted pending resolution of the Quinns’ Motion for Relief from Judgment, a
terrible and uncorre…