Van Horn v. Acctcorp of Southern Nevada et al

Filing 42

ORDER Granting 41 Stipulation re 23 RENEWED MOTION to Dismiss. Replies due by 3/14/2016. Signed by Magistrate Judge Carl W. Hoffman on 2/29/16. (Copies have been distributed pursuant to the NEF - TR)

Case 2:15-cv-02345-RFB-CWH Document 41 Filed 02/26/16 Page 1 of 3

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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 CREDIT
ACCTCORP OF SOUTHERN NEVADA,
BANK OF AMERICA, N.A., CAPITAL COMPANY, LLC, TO FILE ITS
ONE, FORD MOTOR CREDIT COMPANY, REPLY IN SUPPORT OF ITS
LLC,
CITIBANK,
and
EXPERIAN RENEWED MOTION TO
DISMISS
INFORMATION SOLUTIONS, INC.,
vs.

Defendants.

(SECOND REQUEST)

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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);

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Case 2:15-cv-02345-RFB-CWH Document 41 Filed 02/26/16 Page 2 of 3

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 29, 2016;

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

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March 14, 2016, to file its reply;
WHEREAS, Defendant requires more time to obtain the proper documents in

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

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

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will inform Defendant which legal arguments it may appropriately raise in its reply;
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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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WHEREAS, this is Defendant’s second request for an extension of this deadline.

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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 29, 2016, to reply to Plaintiff’s Opposition to Defendant’s

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Motion to Dismiss is hereby vacated;

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Case 2:15-cv-02345-RFB-CWH Document 41 Filed 02/26/16 Page 3 of 3

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(2) Defendant shall have up to and including March 14, 2016, to file its Reply In Support Of Its
Renewed Motion to Dismiss.
IT IS SO STIPULATED.

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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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DATED this 26th day of February, 2016.

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IT IS SO ORDERED.
DATED: February 29, 2016February, 2016.
DATED this
day of

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United States District Judge Judge
United States Magistrate

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