Opinion
Civil Action No. 04-cv-751.
September 16, 2005
PALMER BIEZUP HENDERSON LLP, Stephen M. Calder, Esq., Philadelphia, PA, Attorneys for Plaintiff.
STIPULATION AND CONSENT ORDER TO STAY APPLICATION FOR ENTRY OF DEFAULT JUDGMENT
WHEREAS, the defendant John W. Hatch has not appeared to answer the Complaint against him, in personam, and;
WHEREAS, plaintiff The CIT Corp. ("CIT"), and defendant John W. Hatch are engaged in discussions to attempt to resolve the disputes and claims between them on an amicable basis without the need for further litigation but have not yet reached an agreement.
Now, therefore, plaintiff CIT, by and through its attorneys, hereby stipulates that any application for entry of a default or a judgment by default against defendant John W. Hatch shall be held in abeyance for an additional period of sixty (60) to permit the parties to pursue further discussions, and
Plaintiff CIT respectfully requests this Honorable Court to approve this Stipulation as a Consent Order, to stay the action for a period of sixty (60) days, to retain jurisdiction over the action and to permit the plaintiff CIT to reopen the action within sixty (60) days if no settlement is consummated.