Calkins v. Portfolio Recovery Associates, LLC et al

Filing 40

ORDER Granting 39 Stipulation to Extend Time Re: 34 Motion for Summary Judgment. Responses due by 12/4/2017. Signed by Judge Richard F. Boulware, II on 11/30/2017. (Copies have been distributed pursuant to the NEF - ADR)

1 VERNON A. NELSON, JR., ESQ.
Nevada Bar No.: 6434
2 THE LAW OFFICE OF VERNON NELSON
9480 S. Eastern Ave., Ste. 252
3 Las Vegas, NV 89123
Tel.: [phone]
4 Fax.: [phone]
E-mail: [e-mail]
5 Attorney for Plaintiff Michael Calkins
6

UNITED STATES DISTRICT COURT

7

STATE OF NEVADA

8 MICHAEL CALKINS,
9

Plaintiff,

ATTORNEY AT LAW

THE LAW OFFICE OF VERNON NELSON

10 v.
11 PORTFOLIO RECOVERY ASSOCIATES,
LLC, a foreign limited liability company; and
12 EXPERIAN INFORMATION SERVICES,
INC.
13
Defendants.
14
15

Case No.: 2:16-cv-02628 RFB-VCF

STIPULATION AND ORDER TO
EXTEND TIME FOR PLAINTIFF TO
RESPOND TO MOTION FOR SUMMARY
JUDGMENT
(FIRST REQUEST)

Pursuant to Local Rules IA 6-1, and IA 6-2, the parties, by and through their attorneys of

16 record hereby stipulate and request the court as follows:
17

1.

This is the first stipulation for extension of time to allow Plaintiff MICHAEL

18 CALKINS (“Plaintiff”) to respond to the Motion for Summary Judgment filed by Portfolio Recovery
19 Associates, LLC., (“Defendant”) on November 6, 2017. (ECF No. 34)
20

2.

The Plaintiff’s responsive pleading to the said Motion for Summary Judgment is due

21 on November 27, 2017.
22

3.

The parties agree to extend the Plaintiff’s time to file a responsive pleading to

23 Defendants’ Motion for Summary Judgment in the above-caption matter from November 27, 2017 to
24 December 4, 2017. Good cause exists for this request.
25
26 / / /
27
28 / / /

1

4.

The extension is requested by Plaintiff’s counsel due to a family emergency that has

2 kept him out of the office, and therefore, counsel has been unable to attend to and respond to
3 Defendants’ Motion for Summary Judgment by November 27, 2017. This stipulation is not made for
4 purposes of delay.
5
6

IT IS SO STIPULATED.

7 Dated: this 27th day of November, 2017.
_____
8
9

KRAVITZ, SCHNITZER, & JOHNSON,
CHTD

By: /s/ Gina M. Mushmeche
Gina M. Mushmeche
Nevada Bar No. 10411
8985 S. Eastern Avenue, Suite 200
Las Vegas, NV 89123
Attorneys for Defendant Portfolio Recovery
Associates, LLC

10
11
12
13
14 Dated: this 27th day of November, 2017.
___________________
15

THE LAW OFFICE OF VERNON NELSON, PLLC

16

By: /s/ Vernon Nelson
Vernon Nelson
Nevada Bar No. 6434
9480 South Eastern Avenue, Suite 252
Las Vegas, NV 89123
Attorneys for Plaintiff Michael Calkins

17
18
19
20
21
22
23

IT IS SO ORDERED.
November , 2017.
Dated: This 30th day of
_______________
HON. V. CAM FERENBACH
UNITED STATES MAGISTRATE JUDGE

24
25
26
27
28
2