STIPULATION FOR LIEN PRIORITY AND [PROPOSED] ORDER

JOHN A. MENDEZ, District Judge.

Plaintiff United States of America, Defendant GMAC Mortgage, LLC, and Defendant Sacramento County stipulate as follows:

1. Plaintiff's lawsuit is an action to reduce tax assessments to judgment and to foreclose tax liens that are recorded against real property. See 26 U.S.C. §§ 6502 and 7403.

2. It is agreed that Defendant GMAC Mortgage, LLC is servicing a deed of trust recorded on December 6, 1995 in the Sacramento County Recorder's Office as instrument number 199511091009, which encumbers certain real property located at 6037 White Cloud Court, Citrus Heights, CA 95621 ("Property").

3. It is agreed that Defendant Sacramento County claims an interest in the Property by virtue of statutory liens for delinquent real property taxes assessed against the Property.

4. It is agreed that the statutory liens of Sacramento County referred to in paragraph 3 above are prior and paramount to GMAC Mortgage LLC's deed of trust referred to in paragraph 2 above, as well as the Internal Revenue Service federal tax liens described in paragraphs 54 and 55 of the Complaint.

5. It is agreed that Defendant GMAC Mortgage, LLC's deed of trust referred to in paragraph 2 above is prior and paramount to the Internal Revenue Service federal tax liens described in paragraphs 54 and 55 of the Complaint.

6. Neither Sacramento County nor GMAC Mortgage, LLC oppose judicial foreclosure of the Property by Plaintiff should it prevail in this action. However, because the Plaintiff's interest in the Property is subordinate to the interests of Sacramento County and GMAC Mortgage, LLC, any proceeds from the sale of the Property, as among these three parties, will be used to first pay off the statutory liens held by Sacramento County and then to pay off the loan secured by the GMAC Mortgage, LLC deed of trust before they are used to satisfy the Internal Revenue Service federal tax liens referred to in paragraphs 54 and 55 of the Complaint. Prior to filing an application for final order of the Court, Plaintiff agrees to provide an accounting to GMAC Mortgage, LLC and Sacramento County setting forth the full disposition of the proceeds from the sale of the Property.

7. GMAC Mortgage, LLC and Sacramento County agree to provide Plaintiff with a payoff quote for the amount owing on each loan secured by the deed of trust referred to in paragraph 2 above upon Plaintiff's request prior to the sale of the Property

8. The parties to this stipulation agree to bear their own costs and attorney fees.

9. The parties to this stipulation agree that its contents will bind all their assigns and successors in interest.

10. Upon the execution of this stipulation by all parties and entry of the proposed order by the Court, neither GMAC Mortgage, LLC nor Sacramento County shall be required to appear at any future hearings in this litigation and shall be treated as non-parties for all purposes including discovery purposes, unless ordered by the Court.

IT IS SO STIPULATED.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that on February 17, 2012, I electronically filed the foregoing with the Clerk of Court using the CM/ECF system, which will send notification of such filing to the following:

and that service was made on this date by causing a copy of the foregoing to be sent via postage paid United States first class mail to the following: