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Full Name c/o address city, state phone In propria persona SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES CENTRAL DISTRICT

In re: Pettitioner Full Name,

) ) ) Plaintiffs, ) ) Vs. ) ) JP Morgan Chase Bank, N.A., Bel Air Crest ) ) ) and ) DOES 1 through 100, inclusive, ) ) Defendants. ) _______________________________________)

Case No.: 123456 [Unlimited Civil Action] NOTICE OF MOTION AND MOTION FOR CONTINUANCE Hearing: Date: Time: Dept: Judge: Hon. Black Robe Action Filed: Date of filing of case

The Plaintiffs in the above-captioned case (the Petitioner) hereby notices all parties to this case and moves this Court for entry of an order, pursuant to CCCP 1054 and FRCP Rule 6(b)(1), for the hearing in this matter set for May 14, 2013 and May 15, 2013 be continued to seek counsel and provide counsel adequate time to review the case. JURISDICTION AND VENUE 1. This Court has jurisdiction to consider this Motion for continuance under CCCP 85-86.1. 2. The legal predicates for granting of continuance requested herein are CCCP 1054, FRCP Rule 6(b)(1), in the case of Haines v. Kerner 404 U.S. 519 (1972) the U.S. Supreme Court has ruled that procedural rules should be relaxed for pro se litigants, and in Matter of Sibrun, 18 I&N Dec. 354 (BIA 1983), a motion for continuance based upon an asserted lack of preparation and request for additional time must be supported, at a minimum, by a reasonable showing that the lack of preparation occurred despite a diligent effort to be ready to proceed.

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BACKGROUND 3. Petitioners attorney representative filed a substitution of attorney and withdrew himself from this case, leaving Petitioner with an enormous amount of documents from Defendants to review and respond. Petitioner is overwhelmed due to lack of understanding of the court procedures and the laws. Since Petitioner has been relying on his attorney representative, and, being unschooled in laws, Petitioner has no knowledge and ability to respond and represent himself. The factual background regarding the Petitioner, his reason and need for an extension of time to understand the motion by Defendants and to properly prepare and file his response, is set forth in the Affidavit of Petitioner. RELIEF REQUESTED 4. By this Motion, the Petitioner requests the court to enter an order granting a continuance and move these hearings to July 15, 2013 and beyond, to give Petitioner time to seek counsel and to give his counsel time to review and be familiar with the case and properly prepare and respond to Defendants. APPLICABLE AUTHORITY 5. Under CCCP 1054 and FRCP Rule 6(b)(1) and in Sibrun, 18 I&N Dec. 354 (BIA 1983), the Petitioner may obtain a continuance of hearing for cause shown. 6. Petitioners former attorney has excused himself from this case and left Petitioner with a pile of documents received from Defendants, and being unschooled in law makes it extremely difficult if not impossible to respond to Defendants properly and adequately without understanding. Since Petitioner is unschooled in law, Petitioners last recourse was to seek for counsel to help Petitioner to thoroughly and adequately respond to Defendants. Since petitioner needs additional time to seek counsel, Petitioner submits that cause exists to continue these hearings on July 15, 2013 and beyond. The requested extension of time will allow proper preparation and response and avoid the necessity of subsequent amendments and court time. NO PRIOR REQUEST 7. No previous request for the relief sought herein has been made to this Court. CONCLUSION 8. Therefore, the Petitioner respectfully requests the Court to enter an order granting these hearings to be continued on July 15, 2013, requested in this Motion, and such other and further relief as may be just and proper.

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Dated: May 9, 2013

All Rights Reserved /s/ _________________________ By: Full Name, Petitioner

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MANDATORY JUDICIAL NOTICE(S) Petitioner respectfully requests this Court to take the following Mandatory Judicial Notice(s): WHEREAS: 1. Jenkins v. McKeithen, 395 U.S. 411, 421 (1959); Picking v. Pennsylvania R. Co., 151 Fed 2nd 240; Pucket v. Cox, 456 2nd 233. Pro se pleadings are to be considered without regard to technicality; pro se litigants' pleadings are not to be held to the same high standards of perfection as lawyers. 2. Brotherhood of Trainmen v. Virginia ex rel. Virginia State Bar, 377 U.S. 1; v. Wainwright, 372 U.S. 335; Argersinger v. Hamlin, Sheriff 407 U.S. 425 said that Litigants can be assisted by unlicensed laymen during judicial proceedings. 3. Conley v. Gibson, 355 U.S. 41 at 48 (1957), "Following the simple guide of rule 8(f) that all pleadings shall be so construed as to do substantial justice"... "The federal rules reject the approach that pleading is a game of skill in which one misstep by counsel may be decisive to the outcome and accept the principle that the purpose of pleading is to facilitate a proper decision on the merits." The court also cited Rule 8(f) FRCP, which holds that all pleadings shall be construed to do substantial justice. 4. Puckett v. Cox, 456 F. 2d 233 (1972) (6th Cir. USCA). It was held that a pro se complaint requires a less stringent reading than one drafted by a lawyer per Justice Black in Conley v. Gibson (see case listed above, Pro Se Rights Section). 5. B.Platsky v. CIA, 953 F.2d 25, 26 28 (2nd Cir. 1991), "Court errs if court dismisses pro se litigant without instruction of how pleadings are deficient and how to repair pleadings." 6. In Matter of Sibrun, 18 I&N Dec. 354 (BIA 1983), a motion for continuance based upon an asserted lack of preparation and request for additional time must be supported, at a minimum, by a reasonable showing that the lack of preparation occurred despite a diligent effort to be ready to proceed. 7. In the case of Haines v. Kerner 404 U.S. 519 (1972) the U.S. Supreme Court has ruled that procedural rules should be relaxed for pro se litigants. THEREFORE: Petitioner, Full Name, a pro se litigant and unprepared to submit a proper response to Defendants motion for summary judgment before the hearing on May 14, 2013 and May 15, 2013, requests the Court to grant this matter to be continued on July 15, 2013, to seek counsel and thoroughly and adequately prepare and properly file his response to the Defendants motions for summary judgment. End of Judicial Notices Dated: May 9, 2013 All Rights Reserved /s/ _________________________ By: Full Name, Petitioner

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Full Name c/o address city, state phone In propria persona SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES CENTRAL DISTRICT In re: Full Name

) ) Plaintiffs, ) ) Vs. ) ) JP Morgan Chase Bank, N.A., Bel Air Crest ) ) ) ) ) ) ) Defendants. ) _______________________________________)

[Unlimited Civil Action] AFFIDAVIT OF PETITIONER IN SUPPORT OF MOTION FOR CONTINUANCE Hearing: Date: Time: Dept: Judge: Hon. Black Robe

Action Filed: Filed date

NOTICE TO AGENT IS NOTICE TO PRINCIPAL NOTICE TO PRINCIPAL IS NOTICE TO AGENT The undersigned petitioner, Full Name, hereinafter Affiant, do solemnly swear, declare and state that Affiants is mentally competent and of legal age to state the matters set forth herein, that Affiant has personal firsthand knowledge of the facts stated herein, that Affiant states all of the facts herein to be true, correct, complete, admissible in evidence, and the whole truth and nothing but the truth, presented in good faith with no intent to mislead, in accordance with Affiants beliefs and personal first-hand knowledge and understanding: Affiants attorney withdrew himself as a representative for the plaintiffs in this case and has left plaintiffs with an enormous amount of documents from Defendants in this case to response to. Affiant, being unschooled in law and having little time due to work and parental responsibilities, do not have capacity or ability to properly and timely respond to Defendants Motions for Summary Judgment before the hearing on May 14, 2013 & May 15, 2013 without counsel.

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Affiant, in spite of his diligent effort to prepare on his own, are seeking counsel to help him prepare and adequately file a proper response. With the overwhelming amount of documents filed in this case, Affiant has not been successful in obtaining counsel who would have the time and willing to review and take on this case. Affiant needs additional time to seek for counsel and to give counsel time to get familiar with the case to prepare and file an adequate and proper response. In Matter of Sibrun, 18 I&N Dec. 354 (BIA 1983), a motion for continuance based upon an asserted lack of preparation and request for additional time must be supported, at a minimum, by a reasonable showing that the lack of preparation occurred despite a diligent effort to be ready to proceed. In the case of Haines v. Kerner 404 U.S. 519 (1972) the U.S. Supreme Court has ruled that procedural rules should be relaxed for pro se litigants. THEREFORE, Affiant, Full Name, requests the Court to continue this matter on July 15, 2013, to adequately and properly prepare and file their response to the Defendants Motions for Summary Judgment. Under the pains and penalty of perjury under the laws of the State of California and the Constitution of the United States of America ratified in 1791 with the Bill-of-Rights, Affiants personally prepared and executed the forgoing Affidavit on their unlimited commercial liability. All Rights Reserved ____________________ Date Jurat State of California County of Los Angeles ) ) ss. /s/ ________________________________ By: Full Name, Affiant

Subscribed and affirmed before me on this 9th day of May 2013, by Full Name, proved to me on the basis of satisfactory evidence to be the persons who appeared before me. WITNESS my hand and official seal: ________________________________ Notary Public Signature

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Full Name c/o address city, state phone In propria persona SUPERIOR COURT OF THE STATE OF CALIFORNIA FOR THE COUNTY OF LOS ANGELES CENTRAL DISTRICT In re: Full Name

) ) Plaintiffs, ) ) Vs. ) ) JP Morgan Chase Bank, N.A., Bel Air Crest ) ) ) ) ) ) ) Defendants. ) _______________________________________)

[Unlimited Civil Action] [PROPOSED] ORDER

Hearing: Date: Time: Dept: Judge: Hon. Black Robe Action Filed: Filed date

[PROPOSED] ORDER ON MOTION FOR CONTINUANCE PERSUANT TO CALIFORNIA CODE OF CIVIL PROCEDURE 1054 The Petitioner having filed a motion requesting a continuance, IT IS HEREBY ORDERED as follows: Good cause appearing, pursuant to CCCP 1054 and FEDERAL RULE OF CIVIL PROCEDURE RULE 6(B)(1), a continuance is granted through July 15, 2013 within which to file a response to Motions For Summary Judgment filed by Defendants.

DATED:_________________

______________________________________ Hon. Black Robe, Judge

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PROOF OF SERVICE OF DOCUMENT I am over the age of 18 and not a party to this bankruptcy case or adversary proceeding. My business address is: Full address of servicer A true and correct copy of the foregoing document entitled (specify): NOTICE OF MOTION AND MOTION FOR CONTINUANCE MANDATORY JUDICIAL NOTICE(S) AFFIDAVIT OF PETITIONER [PROPOSED] ORDER will be served or were served in the manner stated below: SERVED BY MAIL: On (date) May 9, 2013 , I personally served the following persons: Name and address of person receiving notice

I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. 5/9/2013 Date Servicers name Printed Name Signature

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