Wells Fargo Bank National Association v. Woodward Family Trust et al

Filing 68

ORDER Granting 67 Stipulation to Extend Time to Submit Dismissal Papers. Submission of dismissal papers deadline extended an additional 45 days. Signed by Magistrate Judge Nancy J. Koppe on 3/7/2018. (Copies have been distributed pursuant to the NEF - SLD)

Case 2:16-cv-02449-GMN-NJK Document 67 Filed 03/07/18 Page 1 of 4

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WRIGHT, FINLAY & ZAK, LLP
Christopher A.J. Swift, Esq.
Nevada Bar No. 11291
Robert A. Riether, Esq.
Nevada Bar No. 12076
7785 W. Sahara Ave., Suite 200
Las Vegas, Nevada 89117
[phone]; Fax: [phone]
[e-mail]
Attorneys for Plaintiff, Wells Fargo Bank National Association, as Trustee for the Holders of the
First Franklin Mortgage Loan Trust 2006-FF15 Mortgage Pass-Through Certificates, Series
2006-FF15

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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WELLS FARGO BANK NATIONAL
ASSOCIATION, AS TRUSTEE FOR THE
HOLDERS OF THE FIRST FRANKLING
MORTGAGE LOAN TRUST 2006-FF15
MORTGAGE PASS-THROUGH
CERTIFICATES, SERIES 2006-FF15,

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2:16-cv-02449-GMN-NJK

STIPULATED REQUEST TO EXTEND
TIME TO SUBMIT DISMISSAL PAPERS

Plaintiff,

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Case No.:

vs.

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RICARDO FOJAS, an individual;
FERDINAND VASQUEZ, an individual;;
HIDDEN CANYON OWNERS
ASSOCIATION, a domestic corporation,

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Defendants.

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COMES NOW, Plaintiff, Wells Fargo Bank National Association, as Trustee for the
Holders of the First Franklin Mortgage Loan Trust 2006-FF15 Mortgage Pass-Through
Certificates, Series 2006-FF15 (hereinafter “Wells Fargo”), Hidden Canyon Owners Association

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(“HOA”), by and through respective counsel of record, and Defendants, Ricardo Fojas and

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Ferdinand Vasquez, (hereinafter “Defendants”); (collectively, the “Parties”), and hereby submit

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their Stipulated Request to Extend Time To Submit Dismissal Papers (the “Stipulation”).

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Case 2:16-cv-02449-GMN-NJK Document 67 Filed 03/07/18 Page 2 of 4

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WHEREAS On January 5, 2018, Wells Fargo filed a Notice of Settlement in this matter.
[Docket No. 62].
WHEREAS On January 17, 2018, this Court issued a minute order, requiring the parties

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submit their dismissal papers by February 5, 2018. [Docket No. 63].

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WHEREAS On February 2, 2018, the Parties jointly filed a Joint Settlement Status
Report with the Court, explaining that the Parties were diligently working on the provisions of
the global settlement agreement and requested sixty (60) additional days to complete and execute
the settlement agreement prior to submitting its dismissal papers. [Docket No. 65].
WHEREAS On February 5, 2018, the Court issued an Order extending the deadline to

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file dismissal papers to March 7, 2018. [Docket No. 66].

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WHEREAS The Parties can now report to the Court that the settlement agreement has

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been finalized by counsel for all parties. It has been executed by Plaintiff, Plaintiff’s counsel,

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Defendant Ricardo Fojas, Defendant Ferdinand Vasquez and agreed to by HOA’s counsel and is

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awaiting signature by HOA.

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THEREFORE IT IS HEREBY STIPULATED AND JOINTLY REQUESTED that
the Parties hereby request an additional forty-five (45) days to complete all signatures, exchange
all settlement monies pursuant to the settlement agreement and file dismissal papers.
I.

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Signatures Pursuant to LR 26-3
This stipulation is signed in accordance with FRCP 26(g)(1) and LR 26-3. Each signature

constitutes a certification that, to the best of the signer’s knowledge, information, and belief,
formed after a reasonable inquiry, the disclosures made by the signer are complete and correct as

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//

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//

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Case 2:16-cv-02449-GMN-NJK Document 67 Filed 03/07/18 Page 3 of 4

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of this time.

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DATED this 7th day of March, 2018.

DATED this 7th day of March, 2018.

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WRIGHT, FINLAY & ZAK, LLP

RICARDO FOJAS
/s/ Ricardo Fojas (with permission)
Ricardo Fojas
2413 Pickwick Drive
Henderson, NV 89014
[e-mail]
Defendant

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/s/ Robert A. Riether, Esq.
Robert A. Riether, Esq.
Nevada Bar No. 12076
7785 W. Sahara Ave., Suite 200
Las Vegas, Nevada 89117
Attorneys for Plaintiff, Wells Fargo Bank
National Association, as Trustee for the
Holders of the First Franklin Mortgage Loan
Trust 2006-FF15 Mortgage Pass-Through
Certificates, Series 2006-FF15

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DATED this 7th day of March, 2018.

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FERDINAND VASQUEZ

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/s/ Ferdinand Vasquez (with permission)
Ferdinand Vasquez
7940 Quail Heaven Street
Las Vegas, NV 89131
Defendant

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DATED this 7th day of March, 2018

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PENGILLY LAW FIRM

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/s/ Elizabeth Lowell, Esq. (With permission)
Elizabeth B. Lowell, Esq.
Nevada Bar No. 8551
1995 Village Center Circle, Suite 190
Las Vegas, NV 89134
Attorneys for Hidden Canyon Homeowners
Association

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IT IS SO ORDERED:

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__________________________________
UNITED STATES MAGISTRATE JUDGE

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March 7, 2018
DATED: _________________________

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