Torno v. Green Tree Servicing, LLC et al

Filing 137

ORDER Granting 136 Stipulation to Extend Time. Motions due by 2/9/2018. Signed by Judge Andrew P. Gordon on 1/10/2018. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:15-cv-01018-APG-PAL Document 136 Filed 01/10/18 Page 1 of 3

1
2
3
4
5
6
7
8
9
10

DENNIS L. KENNEDY
Nevada Bar No. 1462
JOSHUA M. DICKEY
Nevada Bar No. 6621
PAUL C. WILLIAMS
Nevada Bar No. 12524
BAILEYKENNEDY
8984 Spanish Ridge Avenue
Las Vegas, Nevada 89148-1302
Telephone: [phone]
Facsimile: 702.562.8821
[e-mail]
[e-mail]
[e-mail]
[Additional Attorneys on Signature Page]
Attorneys for Plaintiff Crystal Torno
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

11
12

CRYSTAL TORNO (a.k.a. CRYSTAL A.
13 THOMAS-BOLDUC), an individual,
14

Case No. 2:15-cv-01018-APG-PAL
STIPULATION AND ORDER EXTENDING TIME
FOR PLAINTIFF CRYSTAL TORNO TO FILE
MOTION FOR ATTORNEY’S FEES AND COSTS
PURSUANT TO RULE 54

Plaintiff,

15

vs.

16 GREEN TREE SERVICING, LLC;
NATIONAL DEFAULT SERVICING
17 CORPORATION; and PREMIER AMERICAN
TITLE AGENCY, INC., FANNIE MAE; and
18 DOES 1-10, inclusive,
19

(FIRST REQUEST)

Defendants.

20
21

Pursuant to Local Rules IA 6-1, LR 54-1(a), LR 54-14, and Federal Rule of Civil Procedure

22

54, Plaintiff Crystal Torno (“Ms. Torno”), Defendant Green Tree Servicing, LLC (“Green Tree”)

23

and Defendant Federal National Mortgage Association (“Fannie Mae”) (collectively, the “Parties”)

24

hereby stipulate and agree as follows:

25

1.

On December 27, 2017, the Court Clerk entered judgment in favor of Ms. Torno

26

based on her acceptance of an offer of judgment served by Green Tree and Fannie Mae. (ECF No.

27

134.)

28
Page 1 of 3

Case 2:15-cv-01018-APG-PAL Document 136 Filed 01/10/18 Page 2 of 3

1

2.

Pursuant Federal Rule of Civil Procedure 54(d), LR 54-1(a), and LR 54-14, Ms.

2

Torno calculates her deadline to file (i) a Motion for Attorney’s Fees and (ii) a Bill of Costs and

3

Disbursements as January 10, 2018.

4
5

3.

The Parties have engaged in, and continue to engage in, advanced settlement

negotiations to resolve this action and a state court action involving Ms. Torno and Fannie Mae.

6

4.

The Parties hereby stipulate to extend the time allowed for Ms. Torno to file a Motion

7

for Attorney’s Fees and a Bill of Costs and Disbursements from January 10, 2018 to February 9,

8

2018.

9

5.

Green Tree and Fannie Mae object to and dispute the merits of any such motion and

10

Plaintiff’s ability to seek attorneys’ fees and costs. Green Tree and Fannie Mae reserve the right to

11

object, and will object, to any motion for fees and costs that may be filed. Green Tree and Fannie

12

Mae’s stipulation is expressly limited to Plaintiff’s request to extend the deadline to file any such

13

motion.

14

6.

The reason for this request is to accommodate the schedules of Ms. Torno’s counsel

15

and to enable the Parties to continue to engage in settlement negotiations in an effort to resolve this

16

matter, preserving judicial resources and avoiding unnecessary litigation expenses.

17

DATED this 10th day of January, 2018.

18

BAILEYKENNEDY

SNELL & WILMER, L.L.P.

19

By: /s/ Paul C. Williams
DENNIS L. KENNEDY
JOSHUA M. DICKEY
PAUL C. WILLIAMS

By: /s/ Robin E. Perkins
AMY F. SORENSON, ESQ. (Bar No. 12495)
ROBIN E. PERKINS, ESQ. (Bar No. 9891)
V.R. BOHMAN, ESQ. (Bar No. 13075)
3883 Howard Hughes Pkwy, Suite 1100
Las Vegas, Nevada 89169
Phone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants Green Tree Servicing,
LLC and Federal National Mortgage
Association

20
21
22
23
24
25
26

GEORGE H. HAINES
DAVID H. KRIEGER
HAINES & KRIEGER
8985 South Eastern Avenue, Suite 130
Las Vegas, Nevada 89123
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff Crystal Torno

27
28
Page 2 of 3

Case 2:15-cv-01018-APG-PAL Document 136 Filed 01/10/18 Page 3 of 3

1

ORDER

2

IT IS SO ORDERED:

3

The deadline for Ms. Torno to file (i) a Motion for Attorney’s Fees and (ii) a Bill of Costs

4

and Disbursements is extended from January 10, 2018 to February 9, 2018

5
6
7

UNITED STATES DISTRICT JUDGE

8
Dated: 1/10/2018

9
10

Respectfully Submitted by:

11

BAILEYKENNEDY

12

By: /s/ Paul C. Williams
DENNIS L. KENNEDY
JOSHUA M. DICKEY
PAUL C. WILLIAMS

13
14
15
16

HAINES & KRIEGER
GEORGE H. HAINES
DAVID H. KRIEGER
Attorneys for Plaintiffs Crystal Torno

17
18
19
20
21
22
23
24
25
26
27
28
Page 3 of 3