Patton v. Financial Business and Consumer Solutions, Inc.

Filing 40

ORDER Granting 39 Stipulation to Extend Time Re: 38 Motion for Summary Judgment. Responses due by 11/30/2017. Signed by Judge James C. Mahan on 11/16/2017. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-02738-JCM-CWH Document 39 Filed 11/15/17 Page 1 of 3

Tara Clark Newberry, Esq.
NV Bar No. 10696
Clark Newberry Law Firm
7854 W. Sahara Avenue
Las Vegas, NV 89117
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Danny J. Horen
NV Bar No. 13153
Spartan Law, LLC
7854 W. Sahara Avenue
Las Vegas, NV 89117
Telephone: [phone]
Facsimile: 702.548.4459
[e-mail]
Attorneys for Plaintiff
Russell Patton
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
RUSSELL PATTON,
Plaintiff,
v.
FINANCIAL BUSINESS AND
CONSUMER SOLUTIONS, INC.
A/K/A FBCS,
Defendants.

S TIPULATION

Case No.: 2:16-cv-02738-JCM-CWH

[FIRST] STIPULATION TO
EXTEND PLAINTIFF’S TIME TO
RESPOND TO DEFENDANT’S
MOTION FOR SUMMARY
JUDGMENT

Case 2:16-cv-02738-JCM-CWH Document 39 Filed 11/15/17 Page 2 of 3

Plaintiff RUSSEL PATTON (“Plaintiff”) and Defendant FINANCIAL
BUSINESS AND CONSUMER SOLUTIONS, INC. a/k/a FBCS (“Defendant”),
by and through their counsel of record, hereby stipulate as follows:
1. Defendant filed a Motion for Summary Judgment on November 1, 2017.
[Dkt. No. 38];
2. Plaintiff’s Response to Defendant’s Motion for Summary Judgment is
currently due November 22, 2017;
3. Plaintiff deposed Defendant’s Person Most Knowledgeable on November 15,
2017;
4. Plaintiff ordered a “rush copy” of the deposition transcript, which should be
available on or around November 22, 2017;
5. The parties agree that an extension of time to respond to Defendant’s Motion
for Summary Judgment will allow Plaintiff to fully brief its response,
including reviewing and using deposition testimony from Defendant’s
Person Most Knowledgeable;
6. The proposed new deadline for Plaintiff to respond to Defendant’s Motion
under this Stipulation is November 30, 2017;
7. This is the first such request to extend Plaintiff’s deadline to respond to
Defendant’s Motion;
8. This request is made in good faith, with good cause, by the parties to ensure
each party is afforded the opportunity to fully litigate this matter;
S TIPULATION

Case 2:16-cv-02738-JCM-CWH Document 39 Filed 11/15/17 Page 3 of 3

9. This request is not made for the purpose of delay.
Date: November 15, 2017
SPARTAN LAW

MORRIS, POLICH & PURDY
(with permission)

/s/ Danny J. Horen
Danny Horen, Esq.
7854 W. Sahara Avenue
Las Vegas, NV 89117
702.625.1539
Email [e-mail]
Attorney for Plaintiff

/s/ Matthew R. Carlyon
Matthew R. Carlyon, Esq.
3800 Howard Hughes Pkwy
Ste. 500
Las Vegas, NV 89169
Email: [e-mail]
Attorneys for FBCS

IT IS SO ORDERED:
______________________________________
UNITEDMAGISTRATE JUDGE
U.S. STATES DISTRICT JUDGE
November 16, 2017

DATED:___________________________

S TIPULATION