Mott v. The PNC Financial Services Group, Inc. et al

Filing 212

ORDER Granting 211 Stipulation to Extend Time Re: 192 Motion for Judgment, 193 Motion for Partial Summary Judgment, 206 Motion for Sanctions, 205 Motion to Strike. See Order for deadlines. Signed by Judge James C. Mahan on 2/3/2020. (Copies have been distributed pursuant to the NEF - ADR)

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Matthew I. Knepper, Esq.
Nevada Bar No. 12796
Miles N. Clark, Esq.
Nevada Bar No. 13848
KNEPPER & CLARK LLC
5510 So. Fort Apache Rd, Suite 30
Las Vegas, NV 89148
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Email: [e-mail]
David H. Krieger, Esq.
Nevada Bar No. 9086
HAINES & KRIEGER, LLC
8985 S. Eastern Ave., Suite 350
Las Vegas, NV 89123
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
RODNEY MOTT,
Plaintiff,

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Case No. 2:16-cv-01949-JCM-CWH

v.
TRINITY FINANCIAL SERVICES, LLC;
and TROJAN CAPITAL INVESTMENTS,
LLC,
Defendants.

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[FIRST REQUEST]

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Complaint filed: August 16, 2016
TROJAN CAPITAL INVESTMENTS, LLC,
Counterclaimant,

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KNEPPER & CLARK LLC
ATTORNEYS AT LAW
5510 S Fort Apache Rd, Ste 30
Las Vegas, NV 89148
[phone]

[PROPOSED] STIPULATION AND ORDER
TO EXTEND TIME FOR PLAINTIFF TO
FILE REPLY IN SUPPORT OF MOTION
FOR SUMMARY JUDGMENT AND
MOTION FOR JUDGMENT ON THE
PLEADINGS, AND FOR DEFENDANTS TO
FILE RESPONSES TO PLAINTIFF’S
MOTION TO STRIKE AND FOR
SANCTIONS

v.
RODNEY MOTT,
Counterdefendant.

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Plaintiff Rodney Mott (“Plaintiff”), by and through his counsel of record, and Defendants
Trinity Financial Services, LLC; and Trojan Capital Investments, LLC (“Defendants”)
(collectively, the “Parties”) have agreed and stipulated to the following:
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On January 8, 2020, Plaintiff filed his Motion for Partial Summary Judgment. [ECF

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Dkt. 193]

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2.

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[ECF Dkt. 193]

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3.

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4.

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6.

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On January 29, 2020, Plaintiff filed Motions to Strike and for Sanctions. [ECF Dkt.

205, 206]

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On January 29, 2020, the Parties filed their respective Responses to Summary

Judgment. [ECF Dkt. 201, 204]

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On January 10, 2020, the Court granted the Parties’ stipulation for an extension of

time in connection with Plaintiff’s Motion for Judgment on the Pleadings. [ECF Dkt. 200]

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On January 8, 2020, Defendants filed their Motion for Summary Judgment. [ECF

Dkt. 189]

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On January 8, 2020, Plaintiff also filed his Motion for Judgment on the Pleadings.

7.

The Parties’ present summary-judgment Reply deadlines are February 12, 2020,

and Plaintiff’s Reply deadline for his Motion for Judgment on the Pleadings is February 5, 2020.
Defendants’ Response deadlines to Plaintiff’s Motions to Strike and for Sanctions is February 12,
2020.

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The Parties have agreed to extend time for the Parties to file their replies because Plaintiff’s

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counsel has a major appellate opening brief due February 5, 2020, and will be in San Francisco for

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KNEPPER & CLARK LLC
ATTORNEYS AT LAW
5510 S Fort Apache Rd, Ste 30
Las Vegas, NV 89148
[phone]

an oral argument on February 12. The Parties have also agreed that extending Defendants’ time
to respond to Plaintiff’s Motions to Strike and for Sanctions will assist in coordination of motion
practice.
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As a result, both the Parties hereby request this Court to further extend the date for the

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Parties to file (1) their Replies in Support of Motion for Summary Judgment, and (2) Plaintiff’s

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Reply in support of his Motion for Judgement on the Pleadings, and (3) Defendants’ Responses to

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Plaintiff’s Motions to Strike and for Sanctions, until February 17, 2020.

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This stipulation is made in good faith, is not interposed for delay, and is not filed for an
improper purpose
IT IS SO STIPULATED.
Dated January 31, 2020
KNEPPER & CLARK LLC

KOLESAR & LEATHAM

/s/ Miles N. Clark
Matthew I. Knepper, Esq.
Nevada Bar No. 12796
Miles N. Clark, Esq.
Nevada Bar No. 13848
5510 So. Fort Apache Rd, Suite 30
Las Vegas, NV 89148
Email: [e-mail]
Email: [e-mail]

/s/ Michael R. Brooks
Michael R. Brooks, Esq.
Nevada Bar No. 7287
Matthew D. Whittaker, Esq.
Nevada Bar No. 13281
400 S. Rampart Blvd., Suite 400
Las Vegas, NV 89145
Email: [e-mail]
Email: [e-mail]
Counsel for Defendants
Trinity Financial Services, LLC and Trojan
Capital Investments, LLC

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HAINES & KRIEGER LLC
David H. Krieger, Esq.
Nevada Bar No. 9086
8985 S. Eastern Avenue, Suite 350
Las Vegas, NV 89123
Email: [e-mail]

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Counsel for Plaintiff

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ORDER GRANTING

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STIPULATION TO EXTEND TIME FOR PLAINTIFF TO FILE REPLY IN SUPPORT

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OF MOTION FOR SUMMARY JUDGMENT

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IT IS SO ORDERED
_________________________________________
UNITED STATES DISTRICT COURT JUDGE
February 3, of _____________ 2020.
DATED this ____ day 2020.

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KNEPPER & CLARK LLC
ATTORNEYS AT LAW
5510 S Fort Apache Rd, Ste 30
Las Vegas, NV 89148
[phone]

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