Gurshin v. Bank of America, N.A.

Filing 115

ORDER Granting 114 STIPULATION for Extension of Time to file Responses. Responses due 11/10/2016. See Order for details. Signed by Magistrate Judge Cam Ferenbach on 11/8/16. (Copies have been distributed pursuant to the NEF - ADR)

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KATHLEEN J. ENGLAND, Nevada Bar No. 206
ENGLAND LAW OFFICE
610 South Ninth Street
Las Vegas, Nevada 89101
Phone: [phone]
E-mail: [e-mail]
Attorneys for Plaintiff, Alexis Gurshin

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Bethany A. Pelliconi, Pro Hac Vice
Lindsay L. Ryan, Pro Hac Vice
MCGUIRE WOODS LLP
1800 Century Park East, 8th Floor
Los Angeles, California 90067-1501
Attorneys for Defendant, Bank of America, N. A.

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UNITED STATES DISTRICT COURT

ENGLAND LAW OFFICE

ATTORNEYS AT LAW
610 SOUTH NINTH STREET
LAS VEGAS, NEVADA 89101
PHONE [phone]

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DISTRICT OF NEVADA
ALEXIS GURSHIN, Plaintiff,

Case No.: 2:15-cv-00323-GMN-VCF

v.

JOINT STIPULATION TO
EXTEND11/8/16 FILING DEADLINE
BANK OF AMERICA, NATIONAL FOR FILING RFA-RELATED
ASSOCIATION; DOES I through X, and DEADLINES AS ORDERED IN ECF
ROE BUSINESS ENTITIES I through X, NO. 108 AND 113, FOR TWO DAYS
inclusive,
Defendant.
[Second Request]

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Plaintiff Alexis Gurshin (“Plaintiff”) and Defendant, Bank of America, N. A.

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(“Defendant”), through their respective undersigned Counsel, hereby stipulate to request this
Court for a two day extension (to November 10, 2016) of two filing deadlines tomorrow, Election
Day:
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Motion for Order Deeming Admitted Defendant’s Second Set of Requests for

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Admissions to Plaintiff, Or Alternatively, Compelling Responses (ECF No. 106)

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(deadline set Court ORDER, ECF No. 108); and

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The 11/8/16 deadline for Plaintiff to file her response in opposition to Defendant Bank’s

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The 11/8/16 deadline for Plaintiff to file her motion to compel on Defendant’s responses
to Plaintiff’s Requests for Admission, a deadline set in Court ORDER ECF No. 113.

This request is being made because:
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1. Tomorrow, November 8, 2016, is Election Day and undersigned Plaintiff’s Counsel

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is heavily involved in the legal matters both this evening and tomorrow in relation to

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Election Day, and will not be present in the office nor will she have sufficient time

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to additional meet and confer conferences and exchanges, nor to finalize and issue

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the 2nd Supplement to her prior responses Plaintiff intends on issuing;

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2. Counsel for the parties have been meeting and conferring via email and phone

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conferences and this additional time will allow them to narrow the issues in dispute

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which are being submitted to the Court for adjudication.

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Respectfully submitted,

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Dated: November 7, 2016

Dated: November 7, 2016

ENGLAND LAW OFFICE

MCGUIRE WOODS LLP

By: ___/s/___________________________
Kathleen J. England
610 South Ninth Street
Las Vegas, Nevada 89101-7013
Attorneys for Plaintiff,
ALEXIS GURSHIN

By: ___/s/____________________________
Lindsay L. Ryan, Pro Hac Vice
1800 Century Park East, 8th Floor
Los Angeles, California 90067-1501
Attorneys for Defendant,
BANK OF AMERICA, N.A.

ENGLAND LAW OFFICE

ATTORNEYS AT LAW
610 SOUTH NINTH STREET
LAS VEGAS, NEVADA 89101
PHONE [phone]

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IT IS SO ORDERED.
11-8-2016
Dated:

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United States Magistrate Judge

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