8/13/2019 Motion Time Chase Brief

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IN THE STATE OF PENNSYLVANIA

CHESTER COUNTY COMMON PLEAS

JP MORGAN CHASEPlaintiffs,

v.

Tanuja and Timothy Murray,

Defendants

Chester County #12-05579

MOTION FOR TIME EXTENSION

Since your Honor issued his ruling regarding the Petition To Open, we

want to note that the 20 days the Plaintiff had to reply as per your Orderwere not observed by Plaintiff who FedExed a large envelope weighing a few

pounds to us on 8/22/13, and the Court of course will decide if this pleading

is timely on their part by their new counsel, who has asked us to settle and

we are reviewing the issues at bar

However, they sent us this pleading without obtaining a signature so it was

left at our front door which we never use and we just discovered it, so we ask

the Court to allow us 20 days from now to reply to this massive

pleading/reply as we were preparing for the depositions that you ordered to

be completed by the 10/15 hearing.

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Secondly, one of our parents is having a lung transplant today and the care

we must provide her has created a situation where we have been not home

nor available to focus on this issue, so we ask the Court for more time.

Lastly, is it not right that the sheriff sale should be dissolved pending the

outcome of the current litigation? We see it just continued until the DAY

AFTER the hearing itself and that is not possible for even if we were to lose

(we hope this is unlikely as we met all requirements to open the judgment

and also brought to light the assignment proving lack of standing- the

smoking gun that forced them to change lawyers to contain the fraud

damages we are going to sue them for) we would have an appeal available to

us and therefore we ask the court to order the sale stopped pending your

determination, not the prothonotary, as it stands now.

PREPARED BY PRO SE DEFENDANTS

______________ ______________ ______

Timothy Murray Tanuja Murray DATE

CERTIFICATION of SERVICE

We swear under penalty of law that by mail we sent on this day ______ of

September 2013 this Motion to lawyers for CHASE.

DATE ___ By:

_____________ ________________

Tanuja Murray Timothy Murray