JOINT STIPULATION RE RESPONSE BY DEFENDANT BELTLINE ROAD INSURANCE AGENCY, INC. AND SPECIALLY APPEARING DEFENDANT ALTISOURCE PORTFOLIO SOLUTIONS S.A. TO PLAINTIFF'S SECOND AMENDED COMPLAINT

JON S. TIGAR, District Judge.

Plaintiff Margo Perryman ("Plaintiff"), defendant Beltline Road Insurance Agency, Inc. ("Beltline") and specially appearing defendant Altisource Portfolio Solutions S.A. ("Altisource"), through their respective counsel of record, stipulate as follows:

WHEREAS, on October 21, 2014, Plaintiff filed a First Amended Class Action Complaint, including claims against Altisource and Beltline (Dkt. No. 108);

WHEREAS, on February 26, 2015, Altisource filed a motion to dismiss Plaintiff's claims against it pursuant to Rule 12(b)(2), (b)(5) and (b)(1) of the Federal Rules of Civil Procedure (Dkt. No. 176);

WHEREAS, on March 3, 2015, Beltline filed a motion to stay this action as to Altisource and Beltline in light of the pending settlement in Lee v. Ocwen Loan Servicing, LLC, No. 0:14-CV-60649 (S.D. Fla.) ("Lee") (Dkt. No. 178);

WHEREAS, on March 12, 2015, the Court entered an Order (Dkt. No. 180) vacating the briefing schedule and hearing dates on Altisource's motion to dismiss and Beltline's motion to stay and staying this action against Beltline and Altisource pending entry of an order granting or denying final approval of the settlement in Lee;

WHEREAS, on September 14, 2015, Final Judgment was entered in Lee, which enjoins Plaintiff from prosecuting her claims against certain defendants in this action;

WHEREAS, Plaintiff filed a Notice of Appeal in Lee, and filed her opening appellate brief in the 11th Circuit on December 23, 2015;

WHEREAS, on January 15, 2016, Plaintiff filed a Second Amended Class Action Complaint, including claims against Beltline and Altisource;

WHEREAS, Plaintiff, Beltline and Altisource agree that, in light of the stay as to Beltline and Altisource and the pending appellate proceedings in Lee, no response to the Second Amended Complaint by Beltline or Altisource is required at this time;

NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED between Plaintiff, Beltline and Altisource that:

(1) This action shall remain stayed against Beltline and Altisource pending resolution of the appellate proceedings in Lee;

(2) In the event the stay is lifted due to denial of final approval of the settlement in Lee, Beltline and Altisource shall have fourteen (14) days after the date final approval is denied to respond to Plaintiff's Second Amended Complaint pursuant to Rule 12 of the Federal Rules of Civil Procedure; and

(3) Nothing herein shall constitute a waiver of any defense of Altisource, including without limitation defenses based on lack of personal jurisdiction, lack of subject matter jurisdiction and insufficient service of process.

[PROPOSED ORDER]

PURSUANT TO STIPULATION, IT IS SO ORDERED.