AMERICAS (and any predecessors or successors thereto), PHH MORTGAGE CORPORATION, and NEWREZ LLC D/B/A

filing of summons and complaint (the “Complaint”) the action bearing Index Number 653442/2024 (the “Action”); and WHEREAS, on July 10, 2024, Plaintiff served a copy of the complaint on PHH Mortgage Corporation (“PHH”); and WHEREAS, on July 10, 2024, Plaintiff served a copy of the complaint on Newrez LLC d/b/a Shellpoint Mortgage Servicing (“Newrez”); and WHEREAS, on July 8, 2024, Plaintiff served a copy of the complaint on Deutsche Bank Trust Company Americas (“DBTCA”; and together with PHH and Newrez, “Defendants”) WHEREAS, Defendants each filed motions to dismiss on October 18, 2024; and WHEREAS, Plaintiff’s oppositions to the motions to dismiss are due on December 12, 2024; and WHEREAS, this Action is related to several other actions currently before this Court and before Justice Crane (the “Related Actions”); and WHEREAS, on October 30, 2024, oral argument was heard in certain of the Related Actions proceeding before Justice Crane (Part 60); and WHEREAS, at the October 30 oral argument, Justice Crane stated her intention to dismiss the Related Actions currently before her and grant Plaintiffs leave to amend their complaints, with such amended complaints to be filed after the Appellate Division’s ruling in the case captioned Deer Park Rd.

Co. v. Nationstar Mortgage, Index No. 654474/2022 (A.D.1 Case No. 2023-04983) (the “Deer Park Appeal”); and WHEREAS, given the substantial overlap between the various Related Actions, Plaintiff seeks to apply a similar schedule to this Action, and to file an amended complaint after the issuance of decision in the Deer Park Appeal; and WHEREAS, Defendants do not oppose this proposal; and WHEREAS, on November 27, 2024, the Parties wrote to the Court with this proposal; and WHEREAS, on December 2, 2024 (Dkt. No. 93) a Court Notice was issued in which the Court consented to the proposal, set a briefing schedule, and directed that the Parties file a joint stipulation; IT IS HEREBY STIPULATED AND AGREED, by and between counsel for the Parties in these Actions, that: 1.

Defendants hereby withdraw each of the pending motions to dismiss, without prejudice to renew.

Within ten days of Appellate Division’s ruling in the Deer Park Appeal, the Plaintiff shall inform the Court, via letter filed on NYSCEF, whether Plaintiff intends to amend the Complaint, and the anticipated amendments/bases thereto, with citations to any relevant case law.

AMERICAS (and any predecessors or successors thereto), PHH MORTGAGE CORPORATION, and NEWREZ LLC D/B/A

filing of summons and complaint (the “Complaint”) the action bearing Index Number 653442/2024 (the “Action”); and WHEREAS, on July 10, 2024, Plaintiff served a copy of the complaint on PHH Mortgage Corporation (“PHH”); and WHEREAS, on July 10, 2024, Plaintiff served a copy of the complaint on Newrez LLC d/b/a Shellpoint Mortgage Servicing (“Newrez”); and WHEREAS, on July 8, 2024, Plaintiff served a copy of the complaint on Deutsche Bank Trust Company Americas (“DBTCA”; and together with PHH and Newrez, “Defendants”) WHEREAS, Defendants each filed motions to dismiss on October 18, 2024; and WHEREAS, Plaintiff’s oppositions to the motions to dismiss are due on December 12, 2024; and WHEREAS, this Action is related to several other actions currently before this Court and before Justice Crane (the “Related Actions”); and WHEREAS, on October 30, 2024, oral argument was heard in certain of the Related Actions proceeding before Justice Crane (Part 60); and WHEREAS, at the October 30 oral argument, Justice Crane stated her intention to dismiss the Related Actions currently before her and grant Plaintiffs leave to amend their complaints, with such amended complaints to be filed after the Appellate Division’s ruling in the case captioned Deer Park Rd.

Co. v. Nationstar Mortgage, Index No. 654474/2022 (A.D.1 Case No. 2023-04983) (the “Deer Park Appeal”); and WHEREAS, given the substantial overlap between the various Related Actions, Plaintiff seeks to apply a similar schedule to this Action, and to file an amended complaint after the issuance of decision in the Deer Park Appeal; and WHEREAS, Defendants do not oppose this proposal; and WHEREAS, on November 27, 2024, the Parties wrote to the Court with this proposal; and WHEREAS, on December 2, 2024 (Dkt. No. 93) a Court Notice was issued in which the Court consented to the proposal, set a briefing schedule, and directed that the Parties file a joint stipulation; IT IS HEREBY STIPULATED AND AGREED, by and between counsel for the Parties in these Actions, that: 1.

Defendants hereby withdraw each of the pending motions to dismiss, without prejudice to renew.

Within ten days of Appellate Division’s ruling in the Deer Park Appeal, the Plaintiff shall inform the Court, via letter filed on NYSCEF, whether Plaintiff intends to amend the Complaint, and the anticipated amendments/bases thereto, with citations to any relevant case law.

AMERICAS (and any predecessors or successors thereto), and OCWEN LOAN

WHEREAS, on June 27, 2024, Plaintiff Nicole Hart as trustee of the Zittman Family Trust (“Plaintiff”) commenced by filing of summons and complaint (the “Complaint”) the action bearing Index Number 653276/2024 (the “Action”); and WHEREAS, on July 1, 2024, Plaintiff served a copy of the complaint on Ocwen Loan Servicing LLC (“Ocwen”); and WHEREAS, on July 8, 2024, Plaintiff served a copy of the complaint on Deutsche Bank Trust Company Americas (“DBTCA,” and, together with Ocwen, “Defendants”); and WHEREAS, Defendants each filed motions to dismiss on October 18, 2024; and WHEREAS, Plaintiff’s oppositions to the motions to dismiss are due on December 12, 2024; and WHEREAS, this Action is related to several other actions currently before this Court and before Justice Crane (the “Related Actions”); and WHEREAS, on October 30, 2024, oral argument was heard in certain of the Related Actions proceeding before Justice Crane (Part 60); and WHEREAS, at the October 30 oral argument, Justice Crane stated her intention to dismiss the Related Actions currently before her and grant Plaintiffs leave to amend their complaints, with such amended complaints to be filed after the Appellate Division’s ruling in the case captioned Deer Park Rd.

Co. v. Nationstar Mortgage, Index No. 654474/2022 (A.D.1 Case No. 2023-04983) (the “Deer Park Appeal”); and WHEREAS, given the substantial overlap between the various Related Actions, Plaintiff seeks to apply a similar schedule to this Action, and to file an amended complaint after the issuance of decision in the Deer Park Appeal; and WHEREAS, Defendants do not oppose this proposal; and WHEREAS, on November 27, 2024, the Parties wrote to the Court with this proposal; and WHEREAS, on December 2, 2024 (Dkt. No. 81) a Court Notice was issued in which the Court consented to the proposal, set a briefing schedule, and directed that the Parties file a joint stipulation; IT IS HEREBY STIPULATED AND AGREED, by and between counsel for the Parties in these Actions, that: 1.

Defendants hereby withdraw each of the pending motions to dismiss, without prejudice to renew.

Within ten days of Appellate Division’s ruling in the Deer Park Appeal, the Plaintiff shall inform the Court, via letter filed on NYSCEF, whether Plaintiff intends to amend the Complaint, and the anticipated amendments/bases thereto, with citations to any relevant case law.

AMERICAS (and any predecessors or successors thereto), and OCWEN LOAN

WHEREAS, on June 27, 2024, Plaintiff Nicole Hart as trustee of the Zittman Family Trust (“Plaintiff”) commenced by filing of summons and complaint (the “Complaint”) the action bearing Index Number 653276/2024 (the “Action”); and WHEREAS, on July 1, 2024, Plaintiff served a copy of the complaint on Ocwen Loan Servicing LLC (“Ocwen”); and WHEREAS, on July 8, 2024, Plaintiff served a copy of the complaint on Deutsche Bank Trust Company Americas (“DBTCA,” and, together with Ocwen, “Defendants”); and WHEREAS, Defendants each filed motions to dismiss on October 18, 2024; and WHEREAS, Plaintiff’s oppositions to the motions to dismiss are due on December 12, 2024; and WHEREAS, this Action is related to several other actions currently before this Court and before Justice Crane (the “Related Actions”); and WHEREAS, on October 30, 2024, oral argument was heard in certain of the Related Actions proceeding before Justice Crane (Part 60); and WHEREAS, at the October 30 oral argument, Justice Crane stated her intention to dismiss the Related Actions currently before her and grant Plaintiffs leave to amend their complaints, with such amended complaints to be filed after the Appellate Division’s ruling in the case captioned Deer Park Rd.

Co. v. Nationstar Mortgage, Index No. 654474/2022 (A.D.1 Case No. 2023-04983) (the “Deer Park Appeal”); and WHEREAS, given the substantial overlap between the various Related Actions, Plaintiff seeks to apply a similar schedule to this Action, and to file an amended complaint after the issuance of decision in the Deer Park Appeal; and WHEREAS, Defendants do not oppose this proposal; and WHEREAS, on November 27, 2024, the Parties wrote to the Court with this proposal; and WHEREAS, on December 2, 2024 (Dkt. No. 81) a Court Notice was issued in which the Court consented to the proposal, set a briefing schedule, and directed that the Parties file a joint stipulation; IT IS HEREBY STIPULATED AND AGREED, by and between counsel for the Parties in these Actions, that: 1.

Defendants hereby withdraw each of the pending motions to dismiss, without prejudice to renew.

Within ten days of Appellate Division’s ruling in the Deer Park Appeal, the Plaintiff shall inform the Court, via letter filed on NYSCEF, whether Plaintiff intends to amend the Complaint, and the anticipated amendments/bases thereto, with citations to any relevant case law.

AMERICAS (and any predecessors or successors thereto), and OCWEN LOAN

WHEREAS, on June 27, 2024, Plaintiff Nicole Hart as trustee of the Zittman Family Trust (“Plaintiff”) commenced by filing of summons and complaint (the “Complaint”) the action bearing Index Number 653276/2024 (the “Action”); and WHEREAS, on July 1, 2024, Plaintiff served a copy of the complaint on Ocwen Loan Servicing LLC (“Ocwen”); and WHEREAS, on July 8, 2024, Plaintiff served a copy of the complaint on Deutsche Bank Trust Company Americas (“DBTCA,” and, together with Ocwen, “Defendants”); and WHEREAS, Defendants each filed motions to dismiss on October 18, 2024; and WHEREAS, Plaintiff’s oppositions to the motions to dismiss are due on December 12, 2024; and WHEREAS, this Action is related to several other actions currently before this Court and before Justice Crane (the “Related Actions”); and WHEREAS, on October 30, 2024, oral argument was heard in certain of the Related Actions proceeding before Justice Crane (Part 60); and WHEREAS, at the October 30 oral argument, Justice Crane stated her intention to dismiss the Related Actions currently before her and grant Plaintiffs leave to amend their complaints, with such amended complaints to be filed after the Appellate Division’s ruling in the case captioned Deer Park Rd.

Co. v. Nationstar Mortgage, Index No. 654474/2022 (A.D.1 Case No. 2023-04983) (the “Deer Park Appeal”); and WHEREAS, given the substantial overlap between the various Related Actions, Plaintiff seeks to apply a similar schedule to this Action, and to file an amended complaint after the issuance of decision in the Deer Park Appeal; and WHEREAS, Defendants do not oppose this proposal; and WHEREAS, on November 27, 2024, the Parties wrote to the Court with this proposal; and WHEREAS, on December 2, 2024 (Dkt. No. 81) a Court Notice was issued in which the Court consented to the proposal, set a briefing schedule, and directed that the Parties file a joint stipulation; IT IS HEREBY STIPULATED AND AGREED, by and between counsel for the Parties in these Actions, that: 1.

Defendants hereby withdraw each of the pending motions to dismiss, without prejudice to renew.

Within ten days of Appellate Division’s ruling in the Deer Park Appeal, the Plaintiff shall inform the Court, via letter filed on NYSCEF, whether Plaintiff intends to amend the Complaint, and the anticipated amendments/bases thereto, with citations to any relevant case law.