United States of America v. Wells Fargo Bank, N.A. et al

Filing 9

ORDER Granting 8 Joint Motion to Stay. Signed by Judge George W. Foley, Jr. on 10/21/16. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-00628-RFB-GWF Document 8 Filed 10/20/16 Page 1 of 2

1 CAROLINE D. CIRAOLO
Principal Deputy Assistant Attorney General
2
VIRGINIA CRONAN LOWE
3
Trial Attorney, Tax Division
4 U.S. Department of Justice
P.O. Box 683
5 Ben Franklin Station
Washington, D.C. 20044-0683
6 Telephone: [phone]
Facsimile: [phone]
7
[e-mail]
8
DANIEL G. BOGDEN
9 United States Attorney
Of Counsel
10
Attorneys for the United States of America
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12

UNITED STATES DISTRICT COURT

13

DISTRICT OF NEVADA

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CIVIL No. 2:16-cv-00628 RFB-GWF

15 UNITED STATES OF AMERICA,
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Plaintiff,

JOINT MOTION TO STAY AND
[Proposed] ORDER
(Third Request Regarding Deadline to
Answer)

v.

18

WELLS FARGO BANK, N.A., Executor of
19 the Estate of Roy Frank McKoy; ANDREW
NOLL, Trust Officer, Wells Fargo Bank, N.A.,
20
Defendants.
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COMES NOW the United States of America and defendants Wells Fargo Bank, N.A. and
Andrew Noll, by and through their undersigned attorneys, and stipulate as follows:
1. Defendant Wells Fargo Bank, N.A. and defendant Andrew Noll were served with a

26 summons and copy of the Complaint in this matter on June 7, 2016 and June 17, 2016,
27 respectively. Pursuant to an Orders (Docs. 5 and 7) entered on June 28, 2016 and August 15,
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14513977.1

Case 2:16-cv-00628-RFB-GWF Document 8 Filed 10/20/16 Page 2 of 2

1 2016, the time in which the defendants must respond to the Complaint was extended until
2 October 28, 2016.
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2. The parties are continuing with discussions and an exchange of documents regarding a
resolution of this matter. In addition, the defendants are seeking instructions with regard to the

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Estate of Frank McKoy in the District Court, Clark County, Nevada. In order to continue these
discussions without incurring additional fees the parties request that the deadlines in this case,

8 including the time in which the defendants must respond to the Complaint be stayed and the
9 parties be required to file a status report in seventy days or by January 6, 2017
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3. This motion is not meant for delay but to allow the parties additional time to continue
discussions in an effort to resolve this matter without incurring additional costs and expenses.
WHEREFORE, the parties respectfully request that the case be stayed and a status report
be filed by January 6, 2017.
Respectfully submitted this 20th day of October, 2016.

16

CAROLINE D. CIRAOLO
17 Principal Deputy Assistant Attorney General

FENNEMORE CRAIG

18 /s/ Virginia Cronan Lowe
19 VIRGINIA CRONAN LOWE
Trial Attorney, Tax Division
20 U.S. Department of Justice

/s/ Bradley Richardson
BRADLEY RICHARDSON
300 S. Fourth Street, Suite 1400
Las Vegas, NV 89101
Telephone: [phone]

21
DANIEL G. BOGDEN
United States Attorney
23 Of Counsel

Attorneys for Defendants

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24 Attorneys for the United States of America
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IT IS SO ORDERED.
October 21, 2016
Dated: ________________

________________________
GEORGE W. FOLEY
United States Magistrate Judge

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