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

Filing 92

ORDER granting in part and denying in part 91 Stipulation to Extend Time to Respond re 88 Motion for Summary Judgment. For good cause appearing, the parties shall have an extension of fourteen (14) days from the issuance of this Order. Signed by Chief Judge Gloria M. Navarro on 12/27/2017. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:13-cv-01046-GMN-PAL Document 91 Filed 12/19/17 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
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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
SECOND STIPULATION TO EXTEND
PLAINTIFF’S OPPOSITION DUE DATE
TO INTERVENOR DEFENDANT
RESIDENTIAL CREDIT SOLUTIONS,
INC.’S MOTION FOR SUMMARY
JUDGMENT

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STIPULATION

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This Stipulation ((Second Request) is entered into and agreed upon by Kal-Mor-USA, LLC

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(“Plaintiff”), by and through its counsel of record Raffi A. Nahabedian, of the Law Office of Raffi

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A. Nahabedian, as well as by Residential Credit Solutions, Inc. (“Defendant”), by and through its

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counsel of record Christina V. Miller, of the Law Firm Wright Finlay & Zak, LLP. The Stipulation

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is entered into as a means to allow Plaintiff additional time to file and serve its Opposition to

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Defendant’s Motion for Summary Judgment. (ECF 88). The Court approved the First Stipulation

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(ECF 90) for an Opposition due date of December 22, 2017 and a Reply Date of January 8, 2018.

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Page 1 of 3

Case 2:13-cv-01046-GMN-PAL Document 91 Filed 12/19/17 Page 2 of 3

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This Stipulation (Second Request) for an additional thirty (30) day extension of time is

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agreed upon and entered into in good faith by the parties based on the parties continued good faith

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attempts to diligently resolve and settle the pending lawsuit. The proposed new due date for the

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Opposition is January 22, 2018, with a new Reply due date of February 8, 2018.

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This additional time will allow the parties to complete their good faith negotiations, will

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prevent increased litigation costs and, indeed, will reduce the burden on this Court by not having to

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entertain or hear matters that may and can be resolved and settled in the near/immediate future.

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IT IS SO JOINTLY STIPULATED:

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

DATED this 19st day of December 2017.

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RAFFI A. NAHABEDIAN

DATED this 19st day of December 2017.
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.

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ORDER

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IT IS HEREBY ORDERED that the parties' Stipulation is GRANTED in part, and DENIED in

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part. For good cause appearing, the parties shall have an extension of fourteen (14) days from the

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issuance of this Order.
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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By: Raffi A. Nahabedian, Esq.
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 91 Filed 12/19/17 Page 3 of 3

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CERTIFICATE OF SERVICE
I HEREBY CERTIFY that on the 19st day of December, 2017, service of the foregoing
Stipulation (Second Request) 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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