Kosa et al v. American Invsco Corporation et al

Filing 239

ORDER granting 238 Motion to Extend Time to File Motions by an Additional 30 Days. Signed by Judge Andrew P. Gordon on 8/13/2018. (Copies have been distributed pursuant to the NEF - MMM)

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MICHAEL R. MUSHKIN, ESQ.
Nevada Bar No. 2421
L. JOE COPPEDGE, ESQ.
Nevada Bar No. 4954
MUSHKIN CICA COPPEDGE
4495 S. Pecos Road
Las Vegas, Nevada 89121
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]

8 Attorneys for Plaintiffs
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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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BRUCE COUTURIER and ELEANOR
COUTURIER,

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Plaintiffs,

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vs.

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AMERICAN INVSCO, et al.,

Case no.: 2:12-cv-01104-APG-NJK
Consolidated with Case No’s for Trial:
2:12-cv-01106-APG-NJK
2:12-cv-01107-APG-NJK
2:12-cv-01108-APG-NJK
2:12-cv-01110-APG-NJK
2:12-cv-01111-APG-NJK

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Defendants.
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JOINT RULE 6(B)(1) MOTION FOR
EXTENSION OF TIME
PROVIDED BY LR 54-14 &
ORDERS DATED JUNE 28 & 29, 2018
(SECOND REQUEST)

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SHAHIN EDALATDJU and NASILA
EDALATDJU,

Case no.: 2:12-cv-01106-APG-NJK
Consolidated with Case No’s for Trial:

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Plaintiffs,

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vs.

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AMERICAN INVSCO, et al.,

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2:12-cv-01104-APG-NJK
2:12-cv-01107-APG-NJK
2:12-cv-01108-APG-NJK
2:12-cv-01110-APG-NJK
2:12-cv-01111-APG-NJK

Defendants.

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MARY HELDT, VICTOR HELDT, and SNAP
PROPERTIES, LLC, a Nevada Limited
Case no.: 2:12-cv-01107-APG-NJK
Liability Company,
Consolidated with Case No’s for Trial:

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Plaintiffs,

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2:12-cv-01104-APG-NJK
2:12-cv-01106-APG-NJK
2:12-cv-01108-APG-NJK
2:12-cv-01110-APG-NJK
2:12-cv-01111-APG-NJK

vs.

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AMERICAN INVSCO, et al.,

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Defendants.

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NASIR KOSA; BASIL KOSA, and SAID
MATTI,

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Plaintiffs,

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vs.

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AMERICAN INVSCO, et al.,

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Case no.: 2:12-cv-01108-APG-NJK
Consolidated with Case No’s for Trial:
2:12-cv-01104-APG-NJK
2:12-cv-01106-APG-NJK
2:12-cv-01107-APG-NJK
2:12-cv-01110-APG-NJK
2:12-cv-01111-APG-NJK

Defendants.

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WISAM KOSA, RAGHID KOSA and MAHA Case no.: 2:12-cv-01111-APG-NJK
KOSA;
Consolidated with Case No’s for Trial:

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Plaintiffs,

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vs.

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AMERICAN INVSCO, et al.,

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2:12-cv-01104-APG-NJK
2:12-cv-01106-APG-NJK
2:12-cv-01107-APG-NJK
2:12-cv-01108-APG-NJK
2:12-cv-01110-APG-NJK

Defendants.

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JOINT RULE 6(B)(1) MOTION FOR EXTENSION OF TIME
PROVIDED BY LR 54-14 &
ORDERS DATED JUNE 28 & 29, 2018
(SECOND REQUEST)

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The parties, by and through their respective counsel, hereby move for entry of an order

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under FRCP 6(b)(1) extending the periods provided by LR 54-14 and this court’s orders dated

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June 28 & 29, 2018 pertaining to motions for attorney’s fees in each of the above actions, for the

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following reasons:

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1.

These actions have been pending before this court since their removal in October

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2008.

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2.

On June 28 & 29, 2018, the court entered orders and judgments of final

adjudication regarding each of them.

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3.

In those orders, the court instructed Plaintiffs to file motions for attorney’s fees (if

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any) within 14 days (i.e., on or before July 12, 2018 (as to certain of these actions) and July 13,

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2018 (as to the rest). It also instructed Plaintiffs’ counsel to confer with Defendant Meridian’s

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counsel regarding such matters before filing any such motion.

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4.

LR 54-14 provides that motions for attorney’s fees are to be filed within 14 days

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of the entry of a final judgment or order disposing of an action which the United States Supreme

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Court has held is the date of entry of an order disposing of the substantive elements of an action,

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despite the existence or potential for a motion for attorney’s fees. Ray Haluch Gravel Co. v. Cent.

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Pension Fund of Int'l Union of Operating Engineers & Participating Employers, 134 S. Ct. 773

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(2014).

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Counsel for all Plaintiffs and the principal Defendants, Koval Flamingo, LLC and

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Meridian Private Residences CH, LLC have previously requested an extension of time to

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effectively review each parties’ claim(s) for attorney’s fees.

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6.

Counsel for all Plaintiffs and the principal Defendants, Koval Flamingo, LLC and

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Meridian Private Residences CH, LLC have conferred about such matters and are still in

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discussions regarding each parties’ claim(s) for attorney’s fees and that it would unduly burden

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the court and the parties to require such motions to be filed within the period provided by LR 54-

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14 and the court’s orders of June 28 & 29, 2018.

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7.

Accordingly, there is good cause within the meaning of FRCP 6(b)(1) for an

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extension of the period within which to file the parties’ respective motions for attorney’s fees in

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these actions.

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8.

The parties are requesting an additional thirty (30) days to continue discussions

regarding each parties’ claim(s) for attorney’s fees.
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This motion is timely pursuant to FRCP 6(b)(1)(A) in that it has been filed prior

to the expiration of the period for which extension is sought.
Dated this 9th day of August, 2018

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MUSHKIN CICA COPPEDGE
/s/ Michael R. Mushkin
MICHAEL R. MUSHKIN, ESQ.
Nevada State Bar No. 2421
L. JOE COPPEDGE, ESQ.
Nevada State Bar No. 4954
4475 So. Pecos Road
Las Vegas, Nevada 89121

KENNETH B. MORGAN, P.C.
\

/s/ Kenneth B. Morgan
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Kenneth B. Morgan, Esq. (Pro Hac Vice
Admitted)
180 High Oak Drive, Suite 202
Bloomfield Hills, MI 48304
LAWRENCE J. SEMENZA, III, P.C.
Lawrence J. Semenza, III, Esq., Bar No. 7174
Christopher D. Kircher, Esq., Bar No. 11176
Jarrod L. Rickard, Esq., Bar No. 10203
10161 Park Run Drive, Suite 150
Las Vegas, Nevada 89145

Attorneys for Plaintiffs

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Attorneys for Defendant Meridian Private
Residences CH, LLC

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IT IS SO ORDERED.
Dated: August 10, 2018. August, 2018
DATED this ____ day of

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________________________________
UNITED STATES DISTRICT JUDGE

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