Invest Vegas, LLC v. 21st Mortgage Corporation et al

Filing 108

ORDER granting 107 Stipulation; Proposed Joint Pretrial Order due by 8/2/2021. Signed by Magistrate Judge Cam Ferenbach on 7/20/2021. (Copies have been distributed pursuant to the NEF - HAM)

Case 2:15-cv-00644-VCF Document 108 Filed 07/20/21 Page 1 of 4

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GARRETT R. CHASE, ESQ.
Nevada Bar No. 14498
SHUMWAY VAN
8985 South Eastern Avenue, Suite 100
Las Vegas, Nevada 89123
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Attorney for MDM Consultants, Inc.
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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8985 South Eastern Avenue, Suite 100
Las Vegas, Nevada 89123
Telephone: [phone] Facsimile: [phone]

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INVEST VEGAS LLC; MDM
CONSULTANTS, INC.
Case No.: 2:15-cv-00644-VCF
Plaintiff,
v.

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21ST MORTGAGE CORPORATION; CALWESTERN RECONVEYANCE
CORPORATION; NATIONAL CITY
MORTGAGE, A DIVISION OF
NATIONAL CITY BANK OF INDIANA;
COMMONWEALTH LAND TITLE
INSURANCE COMPANY; ONTARIO
CONDOMINIUM RENTAL SERVICES,
INC; HARLEE S. CARTER; LANA
CARTER; DARREN C. BOUTON; DOES I
through X, inclusive; ROE BUSINESS
ENTITIES I through X inclusive.

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STIPULATION AND ORDER TO EXTEND
PRE-TRIAL ORDER DEADLINE

Defendants.

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(THIRD REQUEST)

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Plaintiff MDM Consultants (“Plaintiff”) and Defendant 21st Mortgage Corporation

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(“Defendant”) (collectively, the “Parties”), by and through their respective counsel of record,

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hereby stipulate and agree that the deadline to submit the Joint Pretrial Order in this matter be

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continued by 14 days to allow for the Parties to fully prepare and discuss the various aspects of

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trial. The Parties diligently discussed settlement prospects and participated in mediation which

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concluded without resolution in the afternoon of July 15, 2021. Because of the length of the

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mediation, the Parties have not had a sufficient opportunity to fully and thoroughly review the

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Case 2:15-cv-00644-VCF Document 108 Filed 07/20/21 Page 2 of 4

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various aspects of the Joint Pretrial Order and discuss what evidence will be presented at the time

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of trial. Accordingly, the Parties are requesting that the current deadline to submit the Joint Pretrial

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Order, currently scheduled for July 19, 2021, be extended to August 2, 2021. This is the third

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stipulation of the Parties to continue this deadline. The relevant timeline has not lapsed as of the

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submission of this Stipulation, and this additional time will allow the parties to further confer about

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exhibits and witnesses to be presented at trial, and to timely submit a Joint Pretrial Order. Further,

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this Stipulation complies with the relevant provisions of LR IA 6-1(a) and LR 26-4. Therefore, the

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Parties propose that the deadline for the Joint Pretrial Order be continued until August 2, 2021.

8985 South Eastern Avenue, Suite 100
Las Vegas, Nevada 89123
Telephone: [phone] Facsimile: [phone]

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DATED this 19th day of July, 2021.

DATED this 19th day of July, 2021.

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SHUMWAY VAN

HUTCHINSON & STEFFEN, PLLC

By: /s/ Garrett R. Chase
GARRETT R. CHASE, ESQ.
Nevada Bar No. 14498
8985 S. Eastern Ave., Suite 100
Las Vegas, NV 89123
Attorney for MDM Consultants, Inc.

By: /s/ Michael R. Brooks
MICHAEL R. BROOKS, ESQ.
Nevada Bar No. 7287
8985 S. Eastern Ave., Suite 100
Las Vegas, NV 89123
Attorney for 21st Mortgage Corporation

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Case 2:15-cv-00644-VCF Document 108 Filed 07/20/21 Page 3 of 4

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ORDER
Upon Stipulation of the parties, and for good cause appearing therefore, IT IS HEREBY
ORDERED as follows:

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a. Deadline to for Joint Pretrial Order: August 2, 2021.

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IT IS SO ORDERED.

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______________________________
Cam Ferenbach
United States Magistrate Judge

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8985 South Eastern Avenue, Suite 100
Las Vegas, Nevada 89123
Telephone: [phone] Facsimile: [phone]

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Respectfully Submitted by:

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SHUMWAY VAN
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BY: /s/ Garrett R. Chase
GARRETT R. CHASE, ESQ.
Nevada Bar No. 14498
8985 South Eastern Avenue, Suite 100
Las Vegas, NV 89123
Attorney for MDM Consultants, Inc.

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Case 2:15-cv-00644-VCF Document 108 Filed 07/20/21 Page 4 of 4

From:
To:
Cc:
Subject:
Date:

Michael R. Brooks
Garrett R. Chase
Marina Scott
RE: 21st Mortgage adv. Invest Vegas
Monday, July 19, 2021 2:29:50 PM

This looks fine. 
From: Garrett R. Chase <[e-mail]>
Sent: Monday, July 19, 2021 4:00 PM
To: Michael R. Brooks <[e-mail]>
Cc: Marina Scott <[e-mail]>
Subject: RE: 21st Mortgage adv. Invest Vegas 
Mike,
Attached is the proposed stipulation for your review. If it looks good, let me know and we’ll get it
submitted. 
Best,

Garrett R. Chase, Esq.
Shumway Van

8985 S. Eastern Ave., Suite 100
Las Vegas, Nevada 89123
Ph: [phone]
Fax: [phone]
www.shumwayvan.com
This message and any attached documents contain information from the law firm of Shumway Van that may
be confidential and/or privileged. If you are not the intended recipient, you may not read, copy, distribute, or
use this information. If you have received this transmission in error, please notify the sender immediately by
reply email and then delete this message.  

From: Michael R. Brooks <[e-mail]>
Sent: Monday, July 19, 2021 1:55 PM
To: Garrett R. Chase <[e-mail]>
Cc: Marina Scott <[e-mail]>
Subject: RE: 21st Mortgage adv. Invest Vegas 
Yes, Not sure what happened. Send it over. 
From: Garrett R. Chase <[e-mail]>
Sent: Monday, July 19, 2021 3:49 PM
To: Michael R. Brooks <[e-mail]>
Cc: Marina Scott <[e-mail]>
Subject: RE: 21st Mortgage adv. Invest Vegas