IN THE STATE OF PENNSYLVANIA CHESTER COUNTY COMMON PLEAS

JP MORGAN CHASE Plaintiffs, v. Tanuja and Timothy Murray, Defendants

Chester County #12-05579

MOTION FOR TIME EXTENSION

Since your Honor issued his ruling regarding the Petition To Open, we want to note that the 20 days the Plaintiff had to reply as per your Order were not observed by Plaintiff who FedExed a large envelope weighing a few pounds to us on 8/22/13, and the Court of course will decide if this pleading is timely on their part by their new counsel, who has asked us to settle and we are reviewing the issues at bar

However, they sent us this pleading without obtaining a signature so it was left at our front door which we never use and we just discovered it, so we ask the Court to allow us 20 days from now to reply to this massive pleading/reply as we were preparing for the depositions that you ordered to be completed by the 10/15 hearing.

Secondly, one of our parents is having a lung transplant today and the care we must provide her has created a situation where we have been not home nor available to focus on this issue, so we ask the Court for more time.

Lastly, is it not right that the sheriff sale should be dissolved pending the outcome of the current litigation? We see it just continued until the DAY AFTER the hearing itself and that is not possible for even if we were to lose (we hope this is unlikely as we met all requirements to open the judgment and also brought to light the assignment proving lack of standing- the smoking gun that forced them to change lawyers to contain the fraud damages we are going to sue them for) we would have an appeal available to us and therefore we ask the court to order the sale stopped pending your determination, not the prothonotary, as it stands now. PREPARED BY PRO SE DEFENDANTS ______________ Timothy Murray ______________ Tanuja Murray ______ DATE

CERTIFICATION of SERVICE We swear under penalty of law that by mail we sent on this day ______ of September 2013 this Motion to lawyers for CHASE. DATE ___ By: _____________ Tanuja Murray ________________ Timothy Murray