Collegium Fund Series 32 v. Snyder et al

Filing 42

ORDER Granting 41 Stipulation to Extend Time (Third Request) to Respond to 26 Motion for Summary Judgment. Responses due by 4/18/2017. Signed by Judge James C. Mahan on 3/30/17. (Copies have been distributed pursuant to the NEF - MR)

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Amy F. Sorenson, Esq.
Nevada Bar No. 12495
Nathan G. Kanute, Esq.
Nevada Bar No. 12413
Snell & Wilmer L.L.P.
50 West Liberty Street, Suite 510
Reno, Nevada 89501-1961
Telephone: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
Attorneys for Wells Fargo Bank, N.A. and
Federal Home Loan Mortgage Corporation

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L.L.P.
LAW OFFICES
50 West Liberty Street, Suite 510
Reno, Nevada 89501
775.785.5440

UNITED STATES DISTRICT COURT

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Snell & Wilmer

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DISTRICT OF NEVADA

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COLLEGIUM FUND SERIES 32, a Nevada
limited-liability company,

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Plaintiff,

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v.

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MARK DANIEL SNYDER, an individual;
WELLS FARGO BANK, N.A.; DOES I
THROUGH X; and ROE
CORPORATIONS 1 THROUGH 10,

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(THIRD REQUEST)

WELLS FARGO BANK, N.A., a national
banking association,
Counter-Claimants,

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STIPULATION AND ORDER TO
EXTEND TIME TO RESPOND TO
FEDERAL HOME LOAN
MORTGAGE CORPORATION’S
MOTION FOR SUMMARY
JUDGMENT

Defendants.

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Case No.: 2:16-cv-01640-JCM-PAL

v.
COLLEGIUM FUND SERIES 32, a Nevada
limited-liability company, ABSOLUTE
COLLECTION SERVICES, LLC, a Nevada
limited liability company; NUEVO VISTA
HOMEOWNERS ASSOCIATION, INC., a
Nevada non-profit cooperative corporation,

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Counter-Defendants.

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4811-7251-5141

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FEDERAL HOME LOAN MORTGAGE
CORPORATION,

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Counter-Claimants,
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v.
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COLLEGIUM FUND SERIES 32, a Nevada
limited-liability company, ABSOLUTE
COLLECTION SERVICES, LLC, a Nevada
limited liability company; NUEVO VISTA
HOMEOWNERS ASSOCIATION, INC., a
Nevada non-profit cooperative corporation,

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Counter-Defendants.

L.L.P.
LAW OFFICES
50 West Liberty Street, Suite 510
Reno, Nevada 89501
775.785.5440

Wells Fargo Bank, N.A. (“Wells Fargo”), Federal Home Loan Mortgage Corporation

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Snell & Wilmer

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(“Freddie Mac”), Collegium Fund LLC, Series 32 (“Collegium Fund”), Absolute Collection

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Services, LLC (“ACS”), and Nuevo Vista Homeowners Association, Inc. (the “HOA”), by and

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through their respective counsel, hereby respectfully request that the Court enter an order, pursuant

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to Local Rules 6-1 and 7-1, extending the time for Collegium Fund, ACS, and the HOA to respond

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to the Motion for Summary Judgment (the “MSJ”) filed by Freddie Mac on January 17, 2017 [ECF

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No. 26] and joined by Wells Fargo on January 20, 2017 [ECF No. 29]. The response to the MSJ is

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currently due on March 28, 2017. The Parties have agreed to extend this response date to April 18,

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2017.

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The extension is being sought in good faith and will not unduly delay this litigation. Freddie

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Mac recently discovered additional documents that may be responsive to Collegium Fund’s

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discovery requests. Collegium Fund, the HOA, and ACS would like time to review these additional

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documents before responding to the MSJ. Freddie Mac has now reviewed the documents and

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produced them by mail on March 23, 2017. The requested extension will give Collegium Fund, the

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HOA, and ACS roughly three weeks from receiving the document until responding to the MSJ.
Accordingly, the Parties respectfully request that the Court grant this Stipulation and extend

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the time to respond to the MSJ from March 28, 2017 to April 18, 2017.

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///

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4811-7251-5141

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DATED this 29th day of March, 2017.

/s/ Nathan G. Kanute
Amy F. Sorenson, Esq. (NV Bar No. 12495)
Nathan G. Kanute, Esq. (NV Bar No. 12413)
50 W. Liberty Street, Suite 1510
Reno, NV 89501-1961
Attorneys for Wells Fargo Bank, N.A. and
Federal Home Loan Mortgage Corporation

8 ABSOLUTE COLLECTION SERVICES, LLC

L.L.P.
LAW OFFICES
50 West Liberty Street, Suite 510
Reno, Nevada 89501
775.785.5440

SNELL & WILMER L.L.P.

3 /s/Paul R. Connaghan (with permission)
Paul R. Connaghan, Esq.
4 Nevada Bar No. 3229
Tara D. Newberry, Esq.
5 Nevada Bar No. 10696
7854 W. Sahara Avenue
6 Las Vegas, NV 89117
Attorneys for Collegium #32
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Snell & Wilmer

2 CONNAGHAN|NEWBERRY

PENGILLY LAW FIRM

9 /s/ Shane D. Cox (with permission)___
Shane D. Cox, Esq.
10 Nevada Bar No. 13852
8440 w. Lake Mead Blvd., Ste. 210
11 Las Vegas, NV 89128
Attorneys for Absolute Collection Services
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/s/ Elizabeth B. Lowell (with permission)
Elizabeth B. Lowell, Esq.
Nevada Bar No. 8551
David Markman, Esq.
Nevada Bar No. 12440
1995 Village Center Circle, Ste. 190
Las Vegas, NV 89134
Attorneys for Nuevo Vista HOA

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IT IS SO ORDERED.

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HON. JAMES C. MAHAN
UNITED STATES DISTRICT COURT JUDGE

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DATED:

March 30, 2017

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4811-7251-5141

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CERTIFICATE OF SERVICE

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As an employee of Snell & Wilmer L.L.P., I certify that I served a copy of the foregoing

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STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO FEDERAL HOME

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LOAN MORTGAGE CORPORATION’S MOTION FOR SUMMARY JUDGMENT on the

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29th day of March, 2017 by the method indicated:

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

BY FAX: by transmitting via facsimile the document(s) listed above to the fax
number(s) set forth below on this date before 5:00 p.m. pursuant to EDCR Rule
7.26(a). A printed transmission record is attached to the file copy of this
document(s).

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BY U.S. MAIL: by placing the document(s) listed above in a sealed envelope
with postage thereon fully prepaid, in the United States mail at Reno, Nevada
addressed as set forth below.

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BY OVERNIGHT MAIL: by causing document(s) to be picked up by an
overnight delivery service company for delivery to the addressee(s) on the next
business day.

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BY PERSONAL DELIVERY: by causing personal delivery by
,a
messenger service with which this firm maintains an account, of the document(s)
listed above to the person(s) at the address(es) set forth below.

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BY ELECTRONIC SUBMISSION: submitted to the above-entitled Court for
electronic filing and service upon the Court’s Service List for the above-referenced
case.

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L.L.P.
LAW OFFICES
50 West Liberty Street, Suite 510
Reno, Nevada 89501
775.785.5440

Snell & Wilmer

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Shane D. Cox, Esq.
Absolute Collection Services, LLC
8440 W Lake Mead Blvd Ste 210
Las Vegas, Nevada 89128
James W. Pengilly, Esq.
Elizabeth B. Lowell, Esq.
Pengilly Law Firm
1995 Village Center Cir., Suite 190
Las Vegas, NV 89134
Paul R. Connaghan, Esq.
Tara D. Newberry, Esq.
Connaghan Newberry Law Firm
7854 W Sahara Ave.
Las Vegas, NV 89117
/s/ Lara J. Taylor
An employee of Snell & Wilmer L.L.P.

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4811-7251-5141