Wells Fargo Bank, N.A. v. LV Real Estate Strategic Investment Group LLC Series 2679 et al

Filing 47

ORDER Granting 46 Stipulation to Extend Time re: 33 Motion for Summary Judgment. Responses due by 3/7/2018. Signed by Judge James C. Mahan on 2/8/2018. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-02363-JCM-GWF Document 46 Filed 02/06/18 Page 1 of 5

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JEFF BRAUER ESQ.
Nevada Bar No. 13834
3333 E. Serene Ave. #150
BRAUER, DRISCOLL, SUN AND ASSOCIATES LLC
Henderson, Nevada 89074
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Defendant LV Real Estate Strategic
Investment Group LLC Series 2679
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
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WELLS FARGO BANK, N.A., a national
banking association,
Plaintiff,
vs.
LV REAL ESTATE STRATEGIC
INVESTMENT GROUP LLC SERIES 2679, a
Nevada limited-liability company; REDROCK
PARK HOMEOWNER’S ASSOCIATION, a
Nevada non-profit corporation; ATC
ASSESSMENT COLLECTION GROUP,
LLC, a Nevada limited-liability company;
Defendants.

Case No.: 2:16-cv-02363-JCM-GWF

STIPULATION AND ORDER TO
EXTEND DEADLINE TO FILE
OPPOSITIONS TO PENDING
MOTION FOR SUMMARY
JUDGMENT
(Second Request)

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Defendant LV Real Estate Strategic Investment Group, LLC Series 2679 (hereinafter

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“LV Real Estate”), Defendant Redrock Park Homeowner’s Association (the “HOA”), and

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Plaintiff Wells Fargo Bank, N.A. (“hereinafter Wells Fargo”) (collectively, the “Parties”), by

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and through their respective counsels of record, hereby submit the following second request

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for a Stipulation and Order to extend the deadline for filing oppositions and commensurately

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extending deadlines for filing replies in support of pending dispositive motions.

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THE LAW OFFICES OF
BRAUER DRISCOLL SUN
AND ASSOC LLC
3333 E. Serene Ave. Ste 150
Henderson, 89074
[phone]

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Page 1 of 5

Case 2:16-cv-02363-JCM-GWF Document 46 Filed 02/06/18 Page 2 of 5

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WHEREAS, on December 13, 2017, this Court entered an order (ECF No. 32) setting a
briefing schedule for a dispositive motion based on the federal foreclosure bar.
WHEREAS on December 27, 2017, Wells Fargo filed its Motion for Summary
Judgment. ECF No. 33.

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WHEREAS on January 25, 2018, the Parties filed a first Stipulation for an extension of
time (ECF No. 43) that the Court approved on January 31, 2018 (ECF No. 44) permitting
responses by February 7, 2018.

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WHEREAS, the Parties are in potentially final stages of a settlement negotiation, which

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started in mid-January and which continues to day this Second Request is filed, with terms of

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settlement continuing to narrow significantly such that the parties believe a settlement is both

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possible and now likely.
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THEREFORE, the Parties stipulate and agree to extend the deadlines for opposition to

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Wells Fargo's Motion for Summary Judgment by 30 days to permit the parties time to attempt

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to complete such settlement negotiations.

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WHEREFORE, based on the foregoing,

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IT IS HEREBY STIPULATED AND AGREED that the deadline for oppositions to
Wells Fargo’s Motions for Summary Judgment should be extended to March 7, 2018. And the

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THE LAW OFFICES OF
BRAUER DRISCOLL SUN
AND ASSOC LLC
3333 E. Serene Ave. Ste 150
Henderson, 89074
[phone]

deadline for Wells Fargo to file any reply is 21 days from the date of any opposition, or March
28, 2018. The Parties stipulate and agree to the foregoing in good faith. This Stipulation is
made for the benefit and convenience of the Parties and is not intended to delay the proceedings

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Case 2:16-cv-02363-JCM-GWF Document 46 Filed 02/06/18 Page 3 of 5

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in this case. This is the Parties’ second request to extend the briefing schedule that was

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originally established by the Court’s December 13, 2017 order.

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IT IS SO STIPULATED.

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DATED: February 6, 2018.
SNELL & WILMER L.L.P.
/s/ Wayne Klomp
Wayne Klomp, Esq.
Nevada Bar No. 10109
John S. Delikanakis, Esq.
Nevada Bar No. 5928
Reno, Nevada 89501-1961
Attorneys for Plaintiff Wells Fargo Bank, N.A.

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Thomas E. McGrath, Esq.
Nevada Bar No. 7086
Christopher Ammond Lund
Nevada Bar No. 12435
Las Vegas, Nevada 89123
Attorneys for Defendant
Homeowner’s Association

AND

Jeff Brauer, Esq.
Nevada Bar No. 13834
Henderson, Nevada 89074
Attorneys for Defendant LV Real Estate Strategic
Investment Group LLC

/s/ Christopher Lund

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SUN

TYSON &MENDES LLP

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BRAUER,
DRISCOLL,
ASSOCIATES, LLC
/s/ Jeff Brauer

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Redrock

Park

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Case No.: 2:16-cv-02363-JCM-GWF

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IT IS SO ORDERED:

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_________________________________
UNITED STATES DISTRICT JUDGE,

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February 8, 2018
DATED: _________________

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THE LAW OFFICES OF
BRAUER DRISCOLL SUN
AND ASSOC LLC
3333 E. Serene Ave. Ste 150
Henderson, 89074
[phone]

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Case 2:16-cv-02363-JCM-GWF Document 46 Filed 02/06/18 Page 4 of 5

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Respectfully submitted by:
Brauer, Driscoll, Sun and Associates LLC

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____/s/ Jeff J. Brauer, Esq___________
Jeff Brauer Esq.
Nevada Bar No. 13834
3333 E. Serene Avenue, Suite 150
Henderson, NV 89074
Telephone: [phone]
Attorney for Defendant LV Real Estate Strategic Investment Group LLC Series 2679

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THE LAW OFFICES OF
BRAUER DRISCOLL SUN
AND ASSOC LLC
3333 E. Serene Ave. Ste 150
Henderson, 89074
[phone]

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Case 2:16-cv-02363-JCM-GWF Document 46 Filed 02/06/18 Page 5 of 5

CERTIFICATE OF SERVICE

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I hereby certify that on February 6, 2018, I electronically filed the foregoing with the

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Clerk of Court for the U.S. District Court, District of Nevada by using the Court’s CM/ECF

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system. Participants in the case who are registered CM/ECF users will be served by the

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CM/ECF system.

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/s/ Jeff Brauer
Jeff Brauer, Esq. an employee of BRAUER, DRISCOLL, SUN AND ASSOCIATES LLC

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THE LAW OFFICES OF
BRAUER DRISCOLL SUN
AND ASSOC LLC
3333 E. Serene Ave. Ste 150
Henderson, 89074
[phone]

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