Van Horn v. Acctcorp of Southern Nevada et al

Filing 38

ORDER Granting 37 Stipulation for Extension re 23 RENEWED MOTION to Dismiss. Replies due by 2/29/2016. Signed by Judge Richard F. Boulware, II on 2/15/16. (Copies have been distributed pursuant to the NEF - TR)

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GARY E. SCHNITZER, ESQ.
Nevada Bar No. 395
MATTHEW A. WALKER, ESQ.
Nevada Bar No. 13275
KRAVITZ,SCHNITZER& JOHNSON,CHTD.
8985 S. Eastern Avenue, Suite 200
Las Vegas, Nevada 89123
T. [phone]
F. [phone]
[e-mail]
[e-mail]
Attorneys for Defendant,
FORD MOTOR CREDIT COMPANY, LLC

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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KERRI L. VAN HORN,

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8985 S. Eastern Ave., Ste. 200
Las Vegas, Nevada 89123
(702) 362-66666

KRAVITZ, SCHNITZER & JOHNSON, CHTD.

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Case No. 2:15-cv-02345-RFB-CWH

Plaintiff,
STIPULATION FOR EXTENSION
OF TIME FOR DEFENDANT
FORD MOTOR COMPANY, LLC
ACCTCORP OF SOUTHERN NEVADA,
BANK OF AMERICA, N.A., CAPITAL TO FILE ITS REPLY IN
ONE, FORD MOTOR CREDIT COMPANY, SUPPORT OF ITS RENEWED
LLC,
CITIBANK,
and
EXPERIAN MOTION TO DISMISS
INFORMATION SOLUTIONS, INC.,
(FIRST REQUEST)
vs.

Defendants.

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COMES NOW, Defendant Ford Motor Credit Company, LLC (“Defendant”), and

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Plaintiff Kerri L. Van Horn (“Plaintiff”), by and through their respective counsel, and hereby

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submit this Stipulation for Extension of Time for Defendant Ford Motor Credit Company, LLC

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to File Its Reply In Support Of Its Renewed Motion to Dismiss.

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WHEREAS, this case was removed to this Court on December 9, 2015 (Dkt. #1);

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WHEREAS, Defendant filed its Motion to Dismiss on December 21, 2015 (Dkt. #14);
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WHEREAS, Plaintiff filed her Amended Complaint January 7, 2016 (Dkt. #19);
WHEREAS, Defendant filed its Renewed Motion to Dismiss on January 20, 2016 (Dkt.
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#23);

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WHEREAS, Plaintiff filed its Opposition to Defendant’s Motion to Dismiss on February
5, 2016 (Dkt. #35);

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WHEREAS, Defendant’s current deadline to reply is February 15, 2015;

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WHEREAS, the Parties have stipulated that Defendant shall have up to and including

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February 29, 2016, to file its reply;
WHEREAS, Defendant is in the process of obtaining the proper documents in order to

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address specific issues and arguments raised in Plaintiff’s Amended Complaint and Opposition

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to Defendant’s Renewed Motion to Dismiss. The facts contained in those documents will inform

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Defendant which legal arguments it may appropriately raise in its reply;

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WHEREAS, this is Defendant’s first request for an extension of this deadline.
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8985 S. Eastern Ave., Ste. 200
Las Vegas, Nevada 89123
(702) 362-66666

KRAVITZ, SCHNITZER & JOHNSON, CHTD.

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THEREFORE, in consideration of the foregoing, and for good cause, IT IS HEREBY

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STIPULATED AND AGREED by and between the Parties as follows:

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(1) The current deadline, of February 15, 2016, to reply to Plaintiff’s Opposition to Defendant’s

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Motion to Dismiss is hereby vacated;

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(2) Defendant shall have up to and including February 29, 2016, to file its Reply In Support Of
Its Renewed Motion to Dismiss.
IT IS SO STIPULATED.
DATED this 12th day of February, 2016.

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/s/ Michael Kind
Michael Kind
Nevada Bar No.
KAZEROUNI LAW GROUP
7854 W. Sahara Ave.
Las Vegas, NV 89117
Attorneys for Plaintiff

/s/ Matthew A. Walker
Gary E. Schnitzer, Esq.
Nevada Bar No. 395
Matthew A. Walker
Nevada Bar No. 13275
KRAVITZ, SCHNITZER &
JOHNSON, CHTD.
8985 S. Eastern Ave., Ste. 200
Las Vegas, NV 89123
Attorneys for Defendant

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8985 S. Eastern Ave., Ste. 200
Las Vegas, Nevada 89123
(702) 362-66666

KRAVITZ, SCHNITZER & JOHNSON, CHTD.

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IT IS SO ORDERED.
DATED this 15th

day of February, 2016.

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__________________________
RICHARD F. BOULWARE, II
United States District Judge
United States District Judge

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