Van Zandt v. Quantum Collections, Inc. et al

Filing 17

ORDER Granting 14 Stipulation re 1 Complaint. Barclays Bank, Delaware answer due 7/26/2016. Signed by Magistrate Judge Nancy J. Koppe on 6/30/16. (Copies have been distributed pursuant to the NEF - TR)

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J Christopher Jorgensen
Nevada Bar No. 5382
LEWIS ROCA ROTHGERBER CHRISTIE LLP
3993 Howard Hughes Parkway, Suite 600
Las Vegas, NV 89169
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendant
Barclays Bank Delaware
David H. Krieger, Esq.
Nevada Bar No. 9086
HAINES & KRIEGER, LLC
8985 S. Eastern Ave., Suite 350
Henderson, NV 89123
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff
Maria C. Van Zandt

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IN THE UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MARIA C. VAN ZANDT,
Plaintiff,

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vs.
QUANTUM COLLECTIONS, INC.;
BARCLAYS BANK, DELAWARE;
FORD MOTOR CREDIT-OMAHA
SERVICE CENTER; FORD MOTOR
CREDIT COMPANY; EQUIFAX
INFORMATION SERVICES, LLC;
EXPERIAN INFORMATION
SOLUTIONS, INC.,

Case No.: 2:16-cv-01116-APG-NJK
STIPULATION TO EXTEND
DEFENDANT BARCLAYS
BANK DELAWARE’S TIME TO
RESPOND TO COMPLAINT
(FIRST REQUEST)
Compl. Filed: May 18, 2016

Defendants.

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STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT

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This Stipulation to Extend Time to Respond to Complaint is made by and

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between Plaintiff Maria C. Van Zandt (“Plaintiff”) and Defendant Barclays Bank

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Delaware (“Barclays”) through their respective counsel, in light of the following

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facts:

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RECITALS

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A.

Plaintiff filed the Complaint (“Complaint”) against Barclays on or

about May 18, 2016.

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B.

Barclays was served with the Complaint on June 7, 2016.

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C.

Barclays’ current deadline to respond is June 28, 2016.

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D.

The parties agreed to extend Barclays’ time to respond to the

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Complaint through July 26, 2016, in order to give Barclays time to investigate

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Plaintiff’s claims and prepare a proper response, and for the parties to discuss a

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potential resolution of this matter.

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E.

There is good cause to grant this stipulation because Barclays

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requires additional time to investigate Plaintiff’s claims and prepare a proper

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response, and the parties require additional time to consider a resolution of this

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matter.

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F.

Pursuant to Civil Local Rules 6.2 and 7.1, Plaintiff and Barclays

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respectfully request that the Court extend Barclays’ time to respond to Plaintiff’s

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Complaint through July 26, 2016.

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STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT

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STIPULATION
NOW, THEREFORE, Plaintiff and Barclays hereby stipulate and agree

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that Barclays has up to and including July 26, 2016, to file a response to

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Plaintiff’s Complaint.

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IT IS SO STIPULATED.

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DATED: June 28, 2016

LEWIS ROCA
ROTHGERBER CHRISTIE LLP

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By: /s/ J Christopher Jorgensen
J Christopher Jorgensen
Attorneys for Defendant
Barclays Bank Delaware

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DATED: June 28, 2016

HAINES & KRIEGER, LLC

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By: /s/ David H. Krieger
David H. Krieger, Esq.
Attorneys for Plaintiff
Maria C. Van Zandt

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ORDER
IT IS SO ORDERED.

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UNITED STATES MAGISTRATE JUDGE
UNITED STATES DISTRICT JUDGE

DATE:

June 30, 2016

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STIPULATION TO EXTEND TIME TO RESPOND TO COMPLAINT