STIPULATION AND [PROPOSED] ORDER CONSOLIDATING CASES FOR ALL PURPOSES AND PERMITTING FILING OF CONSOLIDATED COMPLAINT

EDWARD M. CHEN, District Judge.

This Stipulation is entered into by plaintiffs Susan McShannock, as Executrix of the Estate of Patricia Blaskower, and Monica Chandler, as trustee of the Chandler Family Trust, (collectively "Plaintiffs"), and defendant JPMorgan Chase Bank, N.A. by and through their respective counsel;

WHEREAS, the McShannock complaint was filed on March 27, 2018;

WHEREAS, the Chandler complaint was filed on May 9, 2018;

WHEREAS, Plaintiffs have served Defendant in both actions;

WHEREAS, Defendant filed a motion to dismiss the complaint in the McShannock case on May 21, 2018;

WHEREAS counsel for the parties have conferred, and the parties are in agreement that the Chandler action should be consolidated with the McShannock action for all purposes because the cases involve similar complaints and common questions of law or fact, and because consolidation would advance the interests of judicial economy; and

WHEREAS, Plaintiffs intend to file a consolidated complaint, once the cases are consolidated.

IT IS HEREBY STIPULATED AND AGREED, by and between the undersigned counsel for Plaintiffs and Defendant that:

1. The Court has ruled that the following are related cases within the meaning of Local Civil Rule 3-12(a):

2. Pursuant to Federal Rule of Civil Procedure 42(a)(2), the above-captioned actions are hereby consolidated for all purposes into one action.

3. These actions shall be referred to here as the "Consolidated Actions." The Master Docket and Master File for the Consolidated Actions shall be Civil Action No. 3:18-cv-01873-EMC.

4. Upon consolidation of these actions, the Clerk shall administratively close Case No. 3:18-cv-02735-EMC.

5. Every pleading in the Consolidated Actions shall bear the following caption:

6. Defendant has no obligation to respond to the current Complaints. Defendant's motion to dismiss the McShannock Complaint shall be taken off calendar as moot. The case management conference currently scheduled for June 28, 2018 shall be rescheduled to another date convenient for the Court.

7. The Plaintiffs shall file a Consolidated Complaint on or before July 2, 2018. Defendant shall respond to the Consolidated Complaint on or before August 2, 2018.

This stipulation is without prejudice to any other rights that any party may have.

[PROPOSED] ORDER

The above stipulation having been considered and good cause appearing therefore,

IT IS SO ORDERED.

FILER'S ATTESTATION

Pursuant to General Order No. 45, Section X, Subparagraph B, the undersigned attests that all parties have concurred in the filing of this Stipulation and [Proposed] Order Consolidating Cases for All Purposes and Permitting Filing of Consolidated Complaint.

This the 4th day of June, 2018.