Kal-Mor-USA, LLC v. Bank of America, N.A., et al

Filing 90

ORDER Granting 89 Stipulation to Extend Time to Respond/Resply re 88 Motion for Summary Judgment. Responses due by 12/22/2017. Replies due by 1/8/2018. Signed by Chief Judge Gloria M. Navarro on 12/5/2017. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:13-cv-01046-GMN-PAL Document 89 Filed 12/01/17 Page 1 of 3

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RAFFI A. NAHABEDIAN, ESQ.
Nevada Bar No. 009347
LAW OFFICE OF RAFFI A. NAHABEDIAN
10655 Park Run Dr., Suite 210-B
Las Vegas, Nevada 89144
Telephone: [phone]
Facsimile: [phone]

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Attorneys for Plaintiff/Counter-defendant

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IN THE UNITED STATES DISTRICT COURT

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10655 Park Run Dr., Suite 210-B
Las Vegas, Nevada 89144
Tel: [phone] / Fax: [phone]

RAFFI A. NAHABEDIAN

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FOR THE DISTRICT OF NEVADA
KAL-MOR-USA, LLC,

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Plaintiff,
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vs.
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BANK OF AMERICA, N.A., a National
Association; FIDELITY NATIONAL TITLE )
INSURANCE COMPANY, a foreign
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corporation; DOES I through X; and ROE
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CORPORATIONS I through X, inclusive,
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Defendants.
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RESIDENTIAL CREDIT SOLUTIONS,
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INC.
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Intervening Defendant.
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Case No. 2:13-cv-01046-GMN-PAL
STIPULATION TO EXTEND
PLAINTIFF’S OPPOSITION DUE DATE
TO INTERVENOR DEFENDANT
RESIDENTIAL CREDIT SOLUTIONS,
INC.’S MOTION FOR SUMMARY
JUDGMENT

STIPULATION
This Stipulation is entered into and agreed upon by Kal-Mor-USA, LLC (“Plaintiff”), by

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and through its counsel of record Raffi A. Nahabedian, of the Law Office of Raffi A. Nahabedian,

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as well as by Residential Credit Solutions, Inc. (“Defendant”), by and through its counsel of record

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Christina V. Miller, of the Law Firm Wright Finlay & Zak, LLP. The Stipulation is entered into as

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a means to allow Plaintiff additional time to file and serve its Opposition to Defendant’s Motion for

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Summary Judgment. (ECF 88). The stipulated due date for the Opposition is December 22, 2017.

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The stipulated due date for the Reply be on or before January 8, 2018.

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Page 1 of 3

Case 2:13-cv-01046-GMN-PAL Document 89 Filed 12/01/17 Page 2 of 3

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This Stipulation for the extension of time is agreed upon and entered into in good faith by

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the parties based on the parties good faith attempts to diligently resolve and settle the pending

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lawsuit. Such additional time will allow the parties to prevent increased litigation costs and, indeed,

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will reduce the burden on this Court by not having to entertain or hear matters that may and can be

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resolved and settled in the near/immediate future.

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IT IS SO JOINTLY STIPULATED:

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DATED this 1st day of December 2017.

DATED this 1st day of December 2017.

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By: Raffi A. Nahabedian, Esq.

By: Christina V. Miller, Esq.

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Raffi A. Nahabedian, Esq. (SBN 09347)
10655 Park Run Drive, Suite 210-B
Las Vegas, NV 89144
Attorney for Plaintiff
KAL-MOR-USA, LLC

Dana Jonathon Nitz. Esq. (SBN 00050)
Christina V. Miller, Esq. (SBN 12448)
WRIGHT, FINLAY & ZAK, LLP
7785 W. Sahara Avenue, Suite 200
Las Vegas, NV 89117
Attorneys for Intervenor,
RESIDENTIAL CREDIT SOLUTIONS, INC.

10655 Park Run Dr., Suite 210-B
Las Vegas, Nevada 89144
Tel: [phone] / Fax: [phone]

RAFFI A. NAHABEDIAN

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ORDER

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The Stipulation hereinabove set forth is approved and GRANTED.
IT IS SO ORDERED.
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Dated this ___day of December 2017.

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Respectfully Submitted By:

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LAW OFFICE OF RAFFI A. NAHABEDIAN

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By: Raffi A. Nahabedian, Esq.

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Raffi A. Nahabedian, Esq.
Attorney for Plaintiff

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Page 2 of 3

_________________________________
Gloria M. Navarro, Chief Judge
UNITED STATES DISTRICT COURT

Case 2:13-cv-01046-GMN-PAL Document 89 Filed 12/01/17 Page 3 of 3

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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 1st day of December, 2017, service of the foregoing
Stipulation was made this date by electronically serving, through the Court’s/Court Clerk’s
CM/ECF e-file system, a true and correct copy of the same, to the following parties:
Jacob S. Smith, Esq.
Shawn L. Walkenshaw, Esq.
HOUSER & ALLISON
3900 Paradise Road, Suite 101
Las Vegas, NV 89169
[e-mail]
[e-mail]
Attorneys for Intervenor,
RESIDENTIAL CREDIT SOLUTIONS,
INC.

Dana Jonathon Nitz. Esq.
Christina V. Miller, Esq.
WRIGHT, FINLAY & ZAK, LLP
7785 W. Sahara Avenue, Suite 200
Las Vegas, NV 89117
[e-mail]
[e-mail]
Attorneys for Intervenor,
RESIDENTIAL CREDIT SOLUTIONS,
INC.

10655 Park Run Dr., Suite 210-B
Las Vegas, Nevada 89144
Tel: [phone] / Fax: [phone]

RAFFI A. NAHABEDIAN

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/s/ Raffi A. Nahabedian, Esq.
An employee of Raffi A. Nahabedian

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