Collegium Fund Series 32 v. Snyder et al

Filing 47

ORDER Granting 46 Stipulation for Extension of Time re 26 Motion for Summary Judgment (First Request). Replies due by 5/26/2017. Signed by Judge James C. Mahan on 4/26/17. (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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(FIRST REQUEST)

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

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STIPULATION AND ORDER TO
EXTEND TIME TO FILE REPLY IN
SUPPORT OF 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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4811-2057-5303

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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 Freddie Mac to file a reply in support of its

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Motion for Summary Judgment (the “MSJ”) filed by Freddie Mac on January 17, 2017 [ECF No. 26]

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and joined by Wells Fargo on January 20, 2017 [ECF No. 29]. The reply in support of the MSJ is

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currently due on May 5, 2017. The Parties have agreed to extend this response date to May 26, 2017.

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

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Collegium Fund filed its opposition to the MSJ on April 18, 2017 under seal. The opposition is

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roughly 30 pages and raises a number of issues. Freddie Mac is in need of additional time to review

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and respond to the opposition filed by Collegium Fund. Given the volume of litigation related to the

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HOA foreclosures and the issues raised by the opposition, the standard two week reply deadline will

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not offer sufficient time for a Freddie Mac to present its reply. The requested extension will give

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Freddie Mac three weeks additional weeks to prepare the reply, which is commensurate with the

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extensions the Parties agreed to for the oppositions to the MSJ.
Accordingly, the Parties respectfully request that the Court grant this Stipulation and extend

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the time to file a reply in support of the MSJ from May 5, 2017 to May 26, 2017.

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4811-2057-5303

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DATED this 24th day of April, 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/Tara Clark Newberry (with permission)
Paul R. Connaghan, Esq.
4 Nevada Bar No. 3229
Tara Clark 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:

April 26, 2017

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4811-2057-5303

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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 FILE REPLY IN SUPPORT OF

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FEDERAL HOME LOAN MORTGAGE CORPORATION’S MOTION FOR SUMMARY

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JUDGMENT on the 24th day of April, 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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4811-2057-5303