Shirehampton Drive Trust v. JP Morgan Chase Bank N.A. et al

Filing 80

ORDER Granting 79 Stipulation for Extension of Time. Motions due by 1/10/2022. Responses due by 1/31/2022. Replies due by 2/14/2022. Signed by Magistrate Judge Elayna J. Youchah on 1/3/2022. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:16-cv-02276-RFB-EJY Document 80 Filed 01/03/22 Page 1 of 3

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Kent F. Larsen, Esq.
Nevada Bar No. 3463
SMITH LARSEN & WIXOM
1935 Village Center Circle
Las Vegas, Nevada 89134
Tel.: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Defendant/Counterclaimant
JPMorgan Chase Bank, N.A.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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SHIREHAMPTON DRIVE TRUST,
CASE NO.: 2:16-cv-02276-RFB-EJY

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Plaintiff,

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v.
ATTORNEYS
HILLS CENTER BUSINESS PARK
1935 VILLAGE CENTER CIRCLE
LAS VEGAS, NEVADA 89134
[phone] ∙ [phone]

SMITH LARSEN & WIXOM

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JPMORGAN CHASE BANK, NATIONAL
ASSOCIATION; MTC FINANCIAL INC.
DBA TRUSTEE CORPS; and LOUISA
OAKENELL,

STIPULATION AND ORDER TO
EXTEND DEADLINES TO FILE
SUPPLEMENTAL BRIEFS
RE: NOVEMBER 19, 2021 STATUS
HEARING

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Defendants.

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(First Request)

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JPMORGAN CHASE BANK, N.A.,
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Counterclaimant,

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v.

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SHIREHAMPTON DRIVE TRUST; DOES
1 through 10, inclusive; and ROE
CORPORATIONS 1 through 10, inclusive,

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Counterdefendants.
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Plaintiff Shirehampton Drive Trust (“Plaintiff”) and Defendants JPMorgan Chase Bank,
N.A. (“Chase”), by and through their respective counsel of record, hereby agree as follows:

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Case 2:16-cv-02276-RFB-EJY Document 80 Filed 01/03/22 Page 2 of 3

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On November 19, 2022, the Court held a status hearing regarding this matter in

light the Memorandum entered by the Ninth Circuit Court of Appeals in Case No. 19-17253 on

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October 18, 2020 (Docket No. 70).
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2.

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submit supplemental briefs to address certain issues raised by the Ninth Circuit’s Memorandum.

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After discussion at the status hearing, the Court directed Plaintiff and Chase to

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Plaintiff’s counsel submitted his brief on December 20, 2021(Docket No. 78),

but the undersigned counsel for Chase inadvertently (and, apparently, incorrectly) believed that

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the briefing would be sequential (with Chase’s response brief to be filed on January 10, 2022,
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and Plaintiff’s reply (if any) to be filed on January 24, 2022).
4.

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ATTORNEYS
HILLS CENTER BUSINESS PARK
1935 VILLAGE CENTER CIRCLE
LAS VEGAS, NEVADA 89134
[phone] ∙ [phone]

SMITH LARSEN & WIXOM

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The undersigned Counsel have discussed this situation, and respectfully ask this

Court to extend/modify the briefing deadlines and protocol arising from the November 19, 2021
status hearing as follows:

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(i)

Chase’s initial brief (and its opposition to Plaintiff’s December 20, 2021 brief

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(Docket No. 78)) shall be due on Monday, January 10, 2022;

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(ii)

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Plaintiff’s opposition to Chase’s initial brief (and its reply, if any, relative to
Plaintiff’s December 20, 2021 brief) shall be due on Monday, January 31, 2022;

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and,

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(iii)

any reply of Chase (if any) shall be due no later than Monday, February 14,

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2022.

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Case 2:16-cv-02276-RFB-EJY Document 80 Filed 01/03/22 Page 3 of 3

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5.

The parties respectfully submit that the instant stipulation (and the extension set

forth herein) is not requested for purposes of delay, but is submitted in good faith to address an

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inadvertent error in this matter and to allow the parties to orderly brief the issues before the
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Court.

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Dated this 3rd day of January, 2022.

Dated this 3rd day of January, 2022.

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SMITH LARSEN & WIXOM

LAW OFFICES OF MICHAEL F. BOHN,
ESQ., LTD.

/s/ Kent F. Larsen
_
Kent F. Larsen, Esq.
Nevada Bar No. 3463
1935 Village Center Circle
Las Vegas, Nevada 89134
Attorneys for Defendant/Counterclaimant
JPMorgan Chase Bank, N.A.

/s/ Michael F. Bohn
Michael F. Bohn, Esq.
Nevada Bar No. 1641
2260 Corporate Cir., Suite 480
Henderson, Nevada 89074
Attorney for Plaintiff/Counterdefendant
Shirehampton Drive Trust

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ATTORNEYS
HILLS CENTER BUSINESS PARK
1935 VILLAGE CENTER CIRCLE
LAS VEGAS, NEVADA 89134
[phone] ∙ [phone]

SMITH LARSEN & WIXOM

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE

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JUDGE DATED: January 3, 2022.

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