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Filing # 62417810 E-Filed 10/04/2017 05:15:55 PM
IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT
IN AND FOR ORANGE COUNTY, FLORIDA
CIVL ACTION
CASE NO.: 48-2017-CA-008093-O
DIVISION:
U.S. BANK NATIONAL ASSOCIATION, AS
TRUSTEE, ON BEHALF OF THE HOLDERS OF
THE CSMC MORTGAGE.BACKED PASS-
THROUGH CERTIFICATES, SERTES 2007 -3,
Plaintift
vs.
PATRICIA A. HAYWARD-BROWN, et al,
Defendant(s).
I
U.S. Bank National Association, as trustee, on behalf of the holders of the csMC
Plaintiff,
certificates, Series 2oo7-3, moves this Honorable court for an
Mortgage-Backed Pass-Through
Order Staying this case and in support thereof states the following:
2l,2077,Plaintiff filed their initial complaint in this matter'
l. on or about August
the Federal Emergency Management
2. Due to Florida Hunicane Irma (DR-4337),
Agency (FEMA) issued a Major Disaster Declaration on September 10, 2017 '
a
FEMA designated the following counties as in need of Individual Assistance:
Alachua, Baker, Bradford, Brevard, Broward, charlotte, citrus, clay, collier,
Duval, Flagler, Gilchrist, Glades, Hardee, Hendry,
Columbia, DeSoto, Dixie,
Highlands, Hillsborough, Indian River, Lafeyette, Lake, Lee, Levy,
Hernando,
Martin, Miami-Dade, Monroe, Nassau, okeechobee, orange,
Manatee, Marion,
Pasco, Pinellas, Polk, Putnam, Sarasota, Seminole, st' Johns,
osceola, Palm Beach,
St. Lucie, Sumter, Suwannee, Union, and Volusia'
4. FEMA designated the remaining counties of Florida as in need of Public
Assistance.
this loan has been placed on a FEMA Hold due to the aforementioned
5. Accordingly,
Presidential Declaration of Natural Disaster due to Hurricane Irma'
understands that the Court may
6. plaintiff seeks to place a stay on this case, however
have hesitation to indefinitely stay any case'
the Court apprised of the current status of the FEMA Hold on
7. In an effort to keep
Conference be set every
this case, plaintiff respectfully requests that a Case Status
sixty (60) days until the FEMA Hold is removed'
g. The relief requested in this motion is being sought in good faith and not for purposes
of delaY.
g. Plaintiff contends that no party will be prejudiced by the granting of this motion'
allegations constitute good
10. plaintiff respectfully contends that the aforementioned
. cause to extend the 120 day service of process time limit provided by Florida Rule
of Civil Procedure l'0700)'
plaintiff respectfully requests this Honorable Court Grant Plaintiff s
WHEREFORE,
Staying this case and setting a case Status conference
in sixty
Motion to Stay Case, enter an order
(60) days, and for such further relief this court deems just and ploper'
CERTIFICATE OF SERVICE
and correct copy of the foregoingtr-as been furnished to
I HEREBY CERTIFY thalatrue
all parties risted on the attached service list by mail or eservice on this 7 day of october,
2017.
Albertelli Law
P.O. Box 23028
Tampa, FL33623
(st3)22r-4743
(Sl3) 221 -91 7 I facsimile
eservice : servealaw@albertellilaw' com
Lauren M Schroeder
Florida Bar # 0119375
t7-ot6746
Service List
Residential Insurance Company of North^Carolina
United Guaranty
AGENT, CHIEF FINANCIAL OFFICER
C/O REGISTERED
2OO EAST GAINES STREET
TALLATIASSEE, FL32314
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Filing # 62417810 E-Filed 10/04/2017 05:15:55 PM IN THE CIRCUIT COURT OF THE NINTH JUDICIAL CIRCUIT IN AND FOR ORANGE COUNTY, FLORIDA CIVL ACTION CASE NO.: 48-2017-CA-008093-O DIVISION: U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE, ON BEHALF OF THE HOLDERS OF THE CSMC MORTGAGE.BACKED PASS- THROUGH CERTIFICATES, SERTES 2007 -3, Plaintift vs. PATRICIA A. HAYWARD-BROWN, et al, Defendant(s). I U.S. Bank National Association, as trustee, on behalf of the holders of the csMC Plaintiff, certificates, Series 2oo7-3, moves this Honorable court for an Mortgage-Backed Pass-Through Order Staying this case and in support thereof states the following: 2l,2077,Plaintiff filed their initial complaint in this matter' l. on or about August the Federal Emergency Management 2. Due to Florida Hunicane Irma (DR-4337), Agency (FEMA) issued a Major Disaster Declaration on September 10, 2017 ' a FEMA designated the following counties as in need of Individual Assistance: Alachua, Baker, Bradford, Brevard, Broward, charlotte, citrus, clay, collier, Duval, Flagler, Gilchrist, Glades, Hardee, Hendry, Columbia, DeSoto, Dixie, Highlands, Hillsborough, Indian River, Lafeyette, Lake, Lee, Levy, Hernando, Martin, Miami-Dade, Monroe, Nassau, okeechobee, orange, Manatee, Marion, Pasco, Pinellas, Polk, Putnam, Sarasota, Seminole, st' Johns, osceola, Palm Beach, St. Lucie, Sumter, Suwannee, Union, and Volusia' 4. FEMA designated the remaining counties of Florida as in need of Public Assistance. this loan has been placed on a FEMA Hold due to the aforementioned 5. Accordingly, Presidential Declaration of Natural Disaster due to Hurricane Irma' understands that the Court may 6. plaintiff seeks to place a stay on this case, however have hesitation to indefinitely stay any case' the Court apprised of the current status of the FEMA Hold on 7. In an effort to keep Conference be set every this case, plaintiff respectfully requests that a Case Status sixty (60) days until the FEMA Hold is removed' g. The relief requested in this motion is being sought in good faith and not for purposes of delaY. g. Plaintiff contends that no party will be prejudiced by the granting of this motion' allegations constitute good 10. plaintiff respectfully contends that the aforementioned . cause to extend the 120 day service of process time limit provided by Florida Rule of Civil Procedure l'0700)' plaintiff respectfully requests this Honorable Court Grant Plaintiff s WHEREFORE, Staying this case and setting a case Status conference in sixty Motion to Stay Case, enter an order (60) days, and for such further relief this court deems just and ploper' CERTIFICATE OF SERVICE and correct copy of the foregoingtr-as been furnished to I HEREBY CERTIFY thalatrue all parties risted on the attached service list by mail or eservice on this 7 day of october, 2017. Albertelli Law P.O. Box 23028 Tampa, FL33623 (st3)22r-4743 (Sl3) 221 -91 7 I facsimile eservice : servealaw@albertellilaw' com Lauren M Schroeder Florida Bar # 0119375 t7-ot6746 Service List Residential Insurance Company of North^Carolina United Guaranty AGENT, CHIEF FINANCIAL OFFICER C/O REGISTERED 2OO EAST GAINES STREET TALLATIASSEE, FL32314