Collegium Fund Series 32 v. Snyder et al

Filing 62

ORDER Granting 60 Stipulation for Extension of Time re 57 Motion (First Request). Responses due by 9/1/2017. Replies due by 9/29/2017. Signed by Judge James C. Mahan on 8/17/17. (Copies have been distributed pursuant to the NEF - MR)

1
2
3
4
5

CLARK NEWBERRY LAW FIRM
Tara Clark Newberry, Esq. (SBN: 10696)
[e-mail]
7854 West Sahara Avenue
Las Vegas, NV 89117
Telephone: [phone]
Facsimile: [phone]
Attorney for Collegium Fund LLC Series 32

6

UNITED STATES DISTRICT COURT

7

DISTRICT OF NEVADA

8
9

COLLEGIUM FUND SERIES 32, a Nevada
Limited Liability Company,

10
Plaintiff,
11

13
7854 W. Sahara Avenue
Las Vegas, Nevada 89117
Telephone [phone]

CLARK NEWBERRY LAW FIRM

vs.
12

14
15

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

16
17
18

WELLS FARGO BANK, N.A., a national
banking association, and FEDERAL HOME
LOAN MORTGAGE CORPORATION,

19
Counter-Claimants,

20
21
22
23
24
25

vs.
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;

26
Counter-Defendant.
27

)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)
)

28

1

CASE NO.: 2:16-CV-01640-JCM-PAL

STIPULATION AND ORDER TO
EXTEND TIME FOR PLAINTIFF
COLLEGIUM FUND LLC SERIES
32 TO RESPOND TO FREDDIE
MAC AND WELLS FARGO’S
MOTION FOR
RECONSIDERATION OF ORDER
DENYING THEIR MOTION FOR
SUMMARY JUDGMENT [ECF NO.
56]
(FIRST REQUEST)

1

STIPULATION

2
3

The parties, by and through their respective counsel of record, hereby stipulate and request
that this Court enter an order, pursuant to Local Rules 6-1 and 7-1, to extend the time for

4
Plaintiff/Counter-Defendant, COLLEGIUM FUND LLC SERIES 32 (“Collegium #32”), to
5
6

respond to the “Motion for Reconsideration of Order Denying Their Motion for Summary

7

Judgment [ECF No. 56]” (“MFR”) filed by Counterclaimant, FEDERAL HOME LOAN

8

MORTGAGE CORPORATION (“Freddie Mac”) and Defendant, WELLS FARGO BANK, N.A.

9

(“Wells’ Fargo”) on August 2, 2017 as Doc. No. 57. Responses are currently due on August 16,

10

2017. The parties have agreed to extend the time to file responses to September 1, 2017.

11
12
September 29, 2017.
13
7854 W. Sahara Avenue
Las Vegas, Nevada 89117
Telephone [phone]

CLARK NEWBERRY LAW FIRM

Additionally, the parties have agreed that the reply to the response shall be due on or before

14

This is the first request and stipulation to respond to the motion to reconsider this Court’s

15

order denying Freddie Mac and Wells Fargo’s Motion for Summary Judgment. The stipulation and

16

order are necessary to complete the briefing on the complex issues raised and revisited in the

17

MFR. The summer calendar of Collegium #32’s counsel also conflicts with preparing a timely

18

response to the MFR. This request is made in good faith and not submitted for any improper

19
purpose or delay.
20
21

/////

22

/////

23

/////

24

/////

25

/////

26

/////

27
/////
28

2

1

It is so stipulated by the parties that the time to respond to the MFR will be extended from

2

August 16, 2017 to September 1, 2017. It is also stipulated by the parties that the reply to the

3

response shall be due on or before September 29, 2017.

4
5

CLARK NEWBERRY LAW FIRM

SNELL & WILMER L.L.P.

By:
/s/ Tara Clark Newberry
Tara Clark Newberry, Esq.
Nevada Bar No. 10696
7854 W. Sahara Avenue
Las Vegas, NV 89117
Attorneys for
Collegium Fund LLC Series 32

By:
/s/ Nathan G. Kanute
Nathan G. Kanute, Esq.
Nevada Bar No. 1241350 West Liberty
Street, Suite 510
Reno, Nevada 89501-1961
Attorneys for Wells Fargo Bak, N.A. and
Federeal Home Loan Mortgge Corporation

DATED: August 14, 2017

DATED: August 14, 2017

ABSOLUTE COLLECTION SERVICES,
LLC

PENGILLY LAW FIRM

By:
/s/ Shane D. Cox
Shane D. Cox, Esq.
Nevada Bar No. 13852
8440 w. Lake Mead Blvd., Ste. 210
Las Vegas, NV 89128
Attorneys for Absolute Collection Services

By:
/s/ Elizabeth B. Lowell
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

6
7
8
9
10

12
13
7854 W. Sahara Avenue
Las Vegas, Nevada 89117
Telephone [phone]

CLARK NEWBERRY LAW FIRM

11

14
15
16
17
18

DATED: August 14, 2017

19
DATED: August 14, 2017
20
21
22

IT IS SO ORDERED.August 17, 2017.

23
______________________________________________
PEGGY A. LEEN DISTRICT JUDGE
UNITED STATES
UNITED STATES MAGISTRATE JUDGE

24
25
26
27

DATED: _______________

28

3

1

CERTIFICATE OF SERVICE

2

I hereby certify that on the 15th day of August 2017, I electronically submitted the

3

foregoing STIPULATION AND ORDER TO EXTEND TIME FOR PLAINTIFF

4

COLLEGIUM FUND LLC SERIES 32 TO RESPOND TO FREDDIE MAC AND WELLS

5

FARGO’S MOTION FOR RECONSIDERATION OF ORDER DENYING THEIR

6

MOTION FOR SUMMARY JUDGMENT [ECF NO. 56] (FIRST REQUEST) with the clerk
of the court for the U.S. District Court, District of Nevada, using the electronic case file system of

7
the court. The electronic case file system sent a “Notice of Electronic Filing” to the following
8

individuals, who have consented in writing to accept this Notice as service of this document by

9

electronic means.

10
Amy F. Sorenson

[e-mail], [e-mail], [e-mail]
[e-mail]

12

Nathan Guy Kanute

[e-mail], [e-mail], [e-mail]

Craig S Denney

[e-mail]

16

David A Markman

[e-mail], [e-mail],
[e-mail], [e-mail]

17

Elizabeth B Lowell

[e-mail]

18

James W Pengilly

[e-mail]

Shane D. Cox

[e-mail]

13
7854 W. Sahara Avenue
Las Vegas, Nevada 89117
Telephone [phone]

CLARK NEWBERRY LAW FIRM

11

14
15

19
20
21
/s/ Kathleen Seckinger
Kathleen Seckinger, an Employee of
CLARK NEWBERRY LAW FIRM

22
23
24
25
26
27
28

4