Shrager et al v. BSI Financial Services

Filing 14

ORDER Granting 13 Stipulation to Stay Proceedings until 1/5/2017. Signed by Magistrate Judge Cam Ferenbach on 1/3/2017. (Copies have been distributed pursuant to the NEF - SLD)

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ZIEVE, BRODNAX & STEELE, LLP
Benjamin D. Petiprin, Esq.
(NV Bar 11681)
Sherry A. Moore, Esq.
(NV Bar 11215)
3753 Howard Hughes Parkway, Suite 200
Las Vegas, Nevada 89169
Tel: [phone]
Fax: [phone]
Email: [e-mail]
Email: [e-mail]
/

Attorneys for BSI Financial Services

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JAY SHRAGER, an individual; CAROLE B.
SHRAGER, an individual,

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JOINT STIPULATION AND ORDER TO
STAY PROCEEDINGS UNTIL JANUARY 5,
2017

Plaintiffs,

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CASE NO.: 2:16-cv-02039

vs.
BSI FINANCIAL SERVICES an unknown
business entity; DOES I-X, inclusive, ROE
CORPORATIONS I-X, inclusive,

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Defendants.

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Plaintiffs Jay Shrager and Carole B. Shrager (“Plaintiffs”) and Defendant BSI Financial

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Services (“BSI”), by and through their respective counsel of record, hereby stipulate and agree as
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follows:
1.

WHEREAS on September 13, 2016, this court entered the Joint Stipulation and Order to

Stay Proceedings for Sixty Days.

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2.

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litigation.

WHEREAS the parties are engaged in active settlement negotiations to resolve the

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____________________________________________________________________________________

STIPULATION AND ORDER TO STAY PROCEEDINGS - 1 -

3.

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WHEREAS the parties agree to extend the stay through January 5, 2017.

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IT IS THEREFORE STIPULATED AND AGREED:

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1.

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This action is hereby stayed through January 5, 2017. This stay applies to motions,

pleadings, briefings, hearings, appearances, discovery, and any other deadlines imposed by law or this
Court.

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2.

BSI agrees to postpone any foreclosure proceedings with respect to the Property

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pending a potential resolution of the parties’ dispute.
3.

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reach a resolution and that BSI is under no obligation to reach such a resolution.

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Plaintiffs understand that BSI has made no guarantee that the parties will be able to

4.

Should the parties be unable to reach an amicable resolution after expiration January 5,

2016, the parties further stipulate and agree that Plaintiffs and BSI shall each have 20 days from the
expiration of the 60-day deadline to file their Motion to Remand and Motion to Dismiss, respectively.

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///

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///

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____________________________________________________________________________________

STIPULATION AND ORDER TO STAY PROCEEDINGS - 2 -

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5.

The parties further stipulate and agree that the stay requested herein is not requested for

purposes of delay and will not result in any prejudice to the parties or the Court.
IT IS SO STIPULATED.

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DATED: December 30, 2016

ZIEVE, BRODNAX & STEELE, LLP

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By: /s/ Benjamin D. Petiprin
Benjamin D. Petiprin, Esq.
Attorneys for Defendant
BSI Financial Services

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DATED: December 30, 2016

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JENNINGS & FULTON, LTD
By: /s/ Adam Fulton
Adam R. Fulton, Esq.
Attorneys for Plaintiffs
Jay Shrager and Carole B. Shrager

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ORDER

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IT IS SO ORDERED.

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__________________________________
UNITED STATES MAGISTRATE JUDGE

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1-3-2017
DATED: ______________________

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____________________________________________________________________________________

STIPULATION AND ORDER TO STAY PROCEEDINGS - 3 -

CERTIFICATE OF MAILING

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I HEREBY CERTIFY that I am an employee of Zieve, Brodnax & Steele, LLP, and
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not a party to nor interested in the within matter; that on the 30th day of December, 2016,

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service of the JOINT STIPULATION AND ORDER TO STAY PROCEEDINGS UNTIL
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JANUARY 5, 2017 was made by:
(X) by serving the following parties electronically through CM/ECF/WIZNET as set
forth below;
( ) by depositing a copy in the United States Mail postage prepaid to the parties listed
below:

Jared B. Jennings, Esq.
6465 West Sahara Avenue, Suite 103
Las Vegas, NV 89146
Attorney for Jay Shrager and Carole B. Shrager

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/s/ Michele Dapello
Michele Dapello, an employee of
Zieve, Brodnax & Steele, LLP

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____________________________________________________________________________________

CERTIFICATE OF SERVICE