56 NOTICE of Substitution of Attorney

Case 1:15-cv-00293-LTS-RWL Document 56 Filed 06/12/15 Page 1 of 2
UNITED STATES DISTRICT COURT

SOUTHERN DISTRICT OF NEW YORK
MORTGAGE RESOLUTION SERVICING,

LLC, 1ST FIDELITY LOAN SERVICING,
LLC, and S & A CAPITAL PARTNERS, INC.,
Plaintiffs, No. 15-CV-00293(LTS)(JCF)
v.
NOTICE OF MOTION TO
JPMORGAN CHASE BANK, N.A., CHASE SUBSTITUTE COUNSEL
HOME FINANCE, LLC, and JPMORGAN PURSUANT TO LOCAL RULE 1.4
CHASE & CO.,
Defendants.
PLEASE TAKE NOTICE that, on a date and time to be determined by the Court,
Plaintiffs will move before the Hon. Laura Taylor Swain, U.S.D.J., for an order, pursuant to
Local Rule 1.4, permitting Gary F. Eisenberg, Esq., of Perkins Coie LLP, to withdraw as counsel
for Plaintiffs and permitting Helen Davis Chaitman and Lance Gotthoffer, of Becker &
Poliakoff, LLP, to substitute in as counsel of record for Plaintiffs herein.
Plaintiffs will rely upon the accompanying declarations of Laurence Schneider, Gary F.
Eisenberg, Esq. and Lance Gotthoffer, Esq.
Two proposed forms of Consent Order are submitted for the Court’s consideration.
June 12, 2015 Respectfully submitted,
BECKER & POLIAKOFF LLP
By: _/s/ Helen Davis Chaitman

Helen Davis Chaitman, Esq.
Lance Gotthoffer, Esq.
45 Broadway, 8th Floor
New York, New York 10006
Telephone: (212) 599-3322
Facsimile: (212) 557-0295
Email: [email protected]
Email: [email protected]
Attorneys for Plaintiffs
{N0081898 }
Case 1:15-cv-00293-LTS-RWL Document 56 Filed 06/12/15 Page 2 of 2
CERTIFICATION OF SERVICE
I, Helen Davis Chaitman, hereby certify that the foregoing document was filed with
Court via electronic filing on June 12, 2015 and served via email and ECF on all parties of
record.
June 12, 2015 _/s/ Helen Davis Chaitman______________

Helen Davis Chaitman
{N0081898 }
Case 1:15-cv-00293-LTS-RWL Document 56-1 Filed 06/12/15 Page 1 of 1

LLC, 1ST FIDELITY LOAN SERVICING, No. l 5-CV-00293 (LTS)(JCF)
LLC, and S & A CAPITAL PARTNERS,
INC.,
Plaintiffs, DECLARATION OF LAURENCE
SCHNEIDER PURSUANT TO
- V. - 28 USC§ 1746
JPMORGAN CHASE BANK, N.A., CHASE

HOME FINANCE, LLC, and JPMORGAN
CHASE&CO.,
Defendants.
Pursuant to 28 USC Section 1746. L Laurence Schneider, hereby declare as follows:
1. I am the principal of each of the plaintiffs in the above captioned matter.
2. It is my desire to substitute the law firm of Becker& Poliakoff LLP into this
action in place of Perkins Coie LLP as counsel for each of the plaintiffs.
3. I declare under penalty of perjury that the foregoing is true and correct.
........ <
==-
Laurence Schneider
th
Executed this 9 day of June, 2015 in Palm Beach County, Florida.


Plaintiffs, No. 15-CV-00293 {LTS) (JCF)
V.
DECLARATION OF
JPMORGAN CHASE BANK, N.A., CHASE GARY F. EISENBERG
CHASE&CO.,
Defendants.
GARY F. EISENBERG declares under penalty of perjury pursuant to 28 U.S.C. § 1746
that the following is true and correct:
1. I am a member in good standing of the New York State Bar and a partner at the
law firm of Perkins Coie LLP.
2. I submit this declaration in support of Plaintiffs' motion pursuant to Local Rule
1.4, for an order permitting Gary F. Eisenberg, Esq., of Perkins Coie LLP, to withdraw as
counsel for Plaintiffs and permitting the law firm of Becker & Poliakoff, LLP, to substitute in as
counsel of record for Plaintiffs herein.
3. On June 5, 2015, Laurence Schneider, who is a principal of all of the named
Plaintiffs herein, notified me that he would be retaining the services of Becker & Poliakoff, LLP
to replace Perkins Coie as counsel for Plaintiffs herein.
4. I have notified Mr. Schneider and the attorneys at Becker & Poliakoff, LLP that I
consent to the requested substitution of attorney.
5. Mr. Schneider has provided an affidavit confirming his consent to the substitution
of Becker & Poliakoff, LLP as counsel for Plaintiffs herein in accordance with Rule 2(e) of Your
Honor's Individual Practice Rules.
{N0081907 }
6. Given the nascent stage of this litigation, the requested substitution will not
materially impact any deadlines previously set by the Court.
7. Accordingly, I respectfu ll y request that my firm and I be permitted to withdraw as
counsel for Plaintiffs herein and that the Court enter the two consent orders provided.
I declare under penalty of pe1jury that the foregoing stat ments are true and
June 11 , 201 5
{N0081907 }


Plaintiffs, No. 15-CV-00293 (LTS) (JCF)
V.
DECLARATION OF
JPMORGAN CHASE BANK, N.A., CHASE LANCE GOTTHOFFER
CHASE&CO.,
Defendants.
LANCE GOTTHOFFER declares under penalty of perjury pursuant to 28 U.S.C. §
1746 that the following is true and correct:
1. I am a member in good standing of the New York State Bar and of counsel to the
law firm of Becker & Poliakoff, LLP.
2. I submit this declaration in support of Plaintiffs' motion pursuant to Local Rule
1.4, for an order permitting Gary F. Eisenberg, Esq., of Perkins Coie LLP, to withdraw as ____
counsel for Plaintiffs and permitting me and my colleague, Helen Davis Chaitman, also of ·
Becker & Poliakoff, LLP, to substitute in as counsel of record for Plaintiffs herein.
3. On June 5, 2015, I notified Michael C. Nicholson, Esq., Robert D. Wick, Esq. and
Michael M. Maya, Esq. of Covington & Burling LLP, counsel for Defendants that this firm
would be seeking to substitute in as counsel for Plaintiffs in the captioned matter.
4. On June 8, 2015, Mr. Maya advised that the Defendants had no objection to our
substituting in as counsel for Plaintiffs herein.
5. Mr. Laurence Schneider, who is a principal of each of the named Plaintiffs, has
consented to the substitution of Becker & Poliakoff, LLP in place of Perkins Coie LLP as
counsel for each of the named Plaintiffs herein.
{N0081906 }
6. Mr. Eisenberg has submitted a supporting declaration and joins in this request.
I declare under penalty of perjury that the foregoing sta ents are true and correct.
June 11, 2015
{N0081906 }
Ut 'IT ED ST ATES DISTRICT COURT

SOl.-THER'I DISTRICT OF NEW YORK
MORTGAGE RESOU .T ION SE VICING,

LLC. 1ST FID ELITY LOAN SERVI C IJ\;G.
I.LC. and S & 1\ CAPIT AL P/\R T\TR ..... INC ..
Plaintiffs . No. I 5-CV-00293(LTS)(JCF)
V.
CONSEi'\T ORD ER GRANT :'\'G
JP/'vlORG/\N Cf!ASE B;\l\K. N.A .. CH ;\SE St BSTTT l' TION or ATTORl. ·,\'
1-1O\.ll-: FINANCE. LLC, ,me! .IPi•I/IORG.,\l\
CHASE & CO ..
Dclcndants.
Notice is hereby given that. suhiect to approval hy the Court. plaintiffs i\foi, p ge
Resolution Servicing. LI.C, I ' t ridclity Loan Servicing, LLC ;_ind S & A Capital Partners. Inc.
substitutes I lelen Davis Chaitman (State Bar No. 1236678) or Becker & Poliakoff. LL.P. as
counsel of record in place of Gnry F. Fiscnherg. of Perkins Coic LLP.
Contact in fo 1 1ation for new counsel is as follows:
I lei Da\·is Chai ma n

BECK ER & POLIAKOFF, LLP
45 Broad\-~.', 8th Fir.
l\e\\' York. Nc:w York I 0006
Tel: (212)599 -3322
fax: (212) 557-0295
hchai1nrnn a -b11kl.!.:tl.com
l consem to the above substitution .

, '
.,,,..-----
Date: 6 --I --_1'
2- ~
---
I consent to the above substitution.
I consent to the ahc,,-~ substitution.
Date : /;J/1_~
G
[NOOSl8i9 )
The substitution of attorney is hereby approved and so ORDERED.
Date:
----------- Hon. Laura Taylor Swain, U.S.D.J.
(N0081888 }


LLC, l ST PIDELITY LOAN Sl:::RVlClNG,
Plain Li ffs, No. 15-CV-00293(LTS)(JCF)
V.
CONSENT ORDER GRANTING
JPMORGAN CHASE BANK, N.A., CHASE SUBSTITUTION OF ATTORNEY
HOME FfNANCE, LLC, and JPMORGAN
CHASE&CO.,
Defendants.
Notice is hereby given thnL, subject to approval by the Court, plaintiffs Mortgage
Resolution Servicing, LLC, 1st Fidelity Loan Servicing, LLC and S & A Capital Partners, Inc.
substitutes Lance Gotthoffcr (State Bar No. 1088186), of Becker & Poliako ff, LLP, as counsel of
record in place of Gary F. Eisenberg. of Perkins Coie LLP.
Contact information for new counsel is as follows:
Lance Gotthoffcr
BECKER & POLIAKOFF, LLJ>
45 Broadway, 8th Fir.
New York, New York I 0006
Tel: (212)599-3322
Fax: (212) 557-0295
[email protected]
l consent to the above substitution.
Date: _ _ _ _ __ __ _

Date: _.....["---_(...;:_2_· _(_.)---

.,__ _

Date:
- - - - - -- - -
(N0081888 )
The substitution of attorney is hereby approved and so ORDERED.
Date:
- ---- - - ---- Hon. Laura Taylor Swain, U.S.D.J.
{N0081888 )

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Case 1:15-cv-00293-LTS-RWL Document 56 Filed 06/12/15 Page 1 of 2

UNITED STATES DISTRICT COURT

MORTGAGE RESOLUTION SERVICING,

Poliakoff, LLP, to substitute in as counsel of record for Plaintiffs herein.

Eisenberg, Esq. and Lance Gotthoffer, Esq.

June 12, 2015 Respectfully submitted,

BECKER & POLIAKOFF LLP

By: _/s/ Helen Davis Chaitman

June 12, 2015 _/s/ Helen Davis Chaitman______________

UNITED STATES DISTRICT COURT

JPMORGAN CHASE BANK, N.A., CHASE

Pursuant to 28 USC Section 1746. L Laurence Schneider, hereby declare as follows:

1. I am the principal of each of the plaintiffs in the above captioned matter.

UNITED STATES DISTRICT COURT

MORTGAGE RESOLUTION SERVICING,

GARY F. EISENBERG declares under penalty of perjury pursuant to 28 U.S.C. § 1746

that the following is true and correct:

law firm of Perkins Coie LLP.

2. I submit this declaration in support of Plaintiffs' motion pursuant to Local Rule

counsel of record for Plaintiffs herein.

3. On June 5, 2015, Laurence Schneider, who is a principal of all of the named

to replace Perkins Coie as counsel for Plaintiffs herein.

consent to the requested substitution of attorney.

Honor's Individual Practice Rules.

materially impact any deadlines previously set by the Court.

7. Accordingly, I respectfu ll y request that my firm and I be permitted to withdraw as

UNITED STATES DISTRICT COURT

MORTGAGE RESOLUTION SERVICING,

LANCE GOTTHOFFER declares under penalty of perjury pursuant to 28 U.S.C. §

1746 that the following is true and correct:

law firm of Becker & Poliakoff, LLP.

2. I submit this declaration in support of Plaintiffs' motion pursuant to Local Rule

would be seeking to substitute in as counsel for Plaintiffs in the captioned matter.

substituting in as counsel for Plaintiffs herein.

counsel for each of the named Plaintiffs herein.

June 11, 2015

Ut 'IT ED ST ATES DISTRICT COURT

MORTGAGE RESOU .T ION SE VICING,

counsel of record in place of Gnry F. Fiscnherg. of Perkins Coic LLP.

Contact in fo 1 1ation for new counsel is as follows:

I lei Da\·is Chai ma n

l consem to the above substitution .

I consent to the above substitution.

I consent to the ahc,,-~ substitution.

The substitution of attorney is hereby approved and so ORDERED.

UNITED STATES DISTRICT COURT

MORTGAGE RESOLUTION SERVICING,

record in place of Gary F. Eisenberg. of Perkins Coie LLP.

Contact information for new counsel is as follows:

l consent to the above substitution.

I consent to the above substitution.

Date: _.....["---_(...;:_2_· _(_.)---

The substitution of attorney is hereby approved and so ORDERED.

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