Sullivan v. Washington Mutual Bank FA et al

Filing 175

STIPULATION AND ORDER OF DISMISSAL re 174 Stipulation filed by JP Morgan Chase Bank, California Reconveyance Company. Signed by Judge Edward M. Chen on 2/9/16. (bpf, COURT STAFF) (Filed on 2/9/2016)

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JOHN M. SORICH (CA Bar No. 125223)
[e-mail]
MARIEL GERLT-FERRARO (CA Bar No. 251119)
[e-mail]
PARKER IBRAHIM & BERG LLC
695 Town Center Drive, 16th Floor
Costa Mesa, California 92626
Tel: [phone]
Fax: [phone]

Attorneys for Defendants
JPMORGAN CHASE BANK, N.A.,
7 CALIFORNIA RECONVEYANCE COMPANY
and U.S. BANK NATIONAL ASSOCIATION, as
8 Trustee, etc.
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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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KATY SULLIVAN, also known as
KATY MARIE SULLIVAN,

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Plaintiff.

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v.

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WASHINGTON MUTUAL BANK, FA,
JPMORGAN CHASE BANK, National
Association, BANK OF AMERICA,
18 national Association. CALIFORNIA
RECONVEYANCE COMPANY; and
19 Does 1 through 50, inclusive,

CASE NO.: CV 09-2161 EMC
Assigned: Hon. Edward M. Chen
STIPULATION FOR DISMISSAL;
ORDER TO DISMISS AND TO
RETAIN JURISDICTION TO
ENFORCE SETTLEMENT

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Defendants.

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TO THE HONORABLE EDWARD M. CHEN, UNITED STATES DISTRICT

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COURT JUDGE:

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In advance of the February 11, 2016 further case management conference and

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continued hearing on the Order to Show Cause as to why the terms of the settlement

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should not be enforced, the parties submit the following Stipulation for Dismissal.

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Pursuant to Federal Rule of Civil Procedure 41(a)(1)(A)(ii), and based upon the
{00556223.DOCX }

2003.0011

STIPULATION FOR DISMISSAL

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Settlement Agreement between and among the parties to this Stipulation, including

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Defendants JPMorgan Chase Bank, N.A. (“JPMorgan”), California Reconveyance

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Company (“CRC”) and Bank of America, National Association, as successor by

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merger to LaSalle Bank NA as trustee for WaMu Mortgage Pass-Through Certificates

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Series 2006-AR9 Trust (“B of A”) (together, “Defendants”), along with plaintiff Katy

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Sullivan (“Plaintiff”)(collectively the “Parties”), hereby jointly request dismissal of

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this action, with prejudice.

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The Parties further request that the dismissal shall specifically provide however,
that the Court shall retain jurisdiction to enforce this settlement and shall incorporate

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the terms of the Settlement Agreement, and shall be approved and accepted by the

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Court in order to be effective.

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So Stipulated.

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DATED: February 9, 2016

Respectfully submitted,

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PARKER IBRAHIM & BERG LLC

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By: /s/ John M. Sorich
JOHN M. SORICH
MARIEL GERLT-FERRARO
Attorneys for Defendants

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DATED: February 9, 2016

By: /s/ Katy Sullivan
KATY SULLIVAN also known as
KATY MARIE SULLIVAN

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RT

Judge E

ER

{00556223.DOCX }

2003.0011

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. Chen

dward M

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O ORD

IT IS S

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UNIT
ED

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IT IS SO ORDERED:
______________________ICT
S DISTR
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C
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Edward M. Chen
U.S. District Judge
ERED

FO

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N

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STIPULATION FOR DISMISSAL

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PROOF OF SERVICE

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STATE OF CALIFORNIA, COUNTY OF ORANGE
Katy Sullivan v. Washington Mutual Bank, et al.
USDC Northern Case No.: 3:09-cv-02161-EMC

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I am employed in the County of Orange, State of California. I am over the age
of 18 years and not a party to the within action. My business address is Parker
Ibrahim & Berg LLC, 695 Town Center Drive, 16th Floor, Costa Mesa,
6 California 92626.
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On February 9, 2016, I served the foregoing document described as
STIPULATION FOR DISMISSAL; ORDER TO DISMISS AND TO RETAIN
8 JURISDICTION TO ENFORCE SETTLEMENT
on the interested parties in this action.
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

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SEE ATTACHED SERVICE LIST


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BY THE ACT OF FILING OR SERVICE, THAT THE DOCUMENT
WAS PRODUCED ON PAPER PURCHASED AS RECYCLED.

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BY FACSIMILE MACHINE: I Tele-Faxed a copy of the original document
to the above facsimile numbers.

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BY OVERNIGHT MAIL: I deposited such documents at the Golden State
Overnight or Federal Express Drop Box located at 695 Town Center Drive, 16th
Floor, Costa Mesa, California 92626. The envelope was deposited with delivery
fees thereon fully prepaid.



BY CM/ECF ELECTRONIC DELIVERY: In accordance with the registered
case participants and in accordance with the procedures set forth at the Court’s
website www.ecf.cacd.uscourts.gov



(Federal) I declare that I am employed in the office of a member of the Bar of
this Court, at whose direction the service was made.

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BY REGULAR MAIL: I deposited such envelope in the mail at 695 Town
Center Drive, 16th Floor, Costa Mesa, California 92626. The envelope was
mailed with postage thereon fully prepaid.
I am “readily familiar” with the firm’s practice of collection and processing
correspondence for mailing. It is deposited with the U.S. Postal Service on that
same day in the ordinary course of business. I am aware that on motion of the
party served, service is presumed invalid if postal cancellation date or postage
meter date is more than one (1) day after date of deposit for mailing in affidavit.

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by placing the original and/or a true copy thereof enclosed in (a) sealed
envelope(s), addressed as follows:

Executed on February 9, 2016, at Costa Mesa, California.
/s/ Heather Kane
Heather Kane

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{00556223.DOCX }

2003.0011

PROOF OF SERVICE

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SERVICE LIST
Katy Sullivan v. Washington Mutual Bank, et al.
USDC Northern Case No.: 3:09-cv-02161-EMC

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Katy M. Sullivan
2628 Sutter St., B
6 San Francisco, CA 94115
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Tel: [phone]
[e-mail]
Pro Per

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{00556223.DOCX }

2003.0011

PROOF OF SERVICE