Deutsche Bank National Trust Company v. Premier One Holdings Inc. et al

Filing 42

ORDER Granting 41 Stipulation to Stay Discovery. IT IS ORDERED that this case is stayed for 90 days, or until 4/12/2018. IT IS FURTHER ORDERED that the parties shall have until 5/14/2018, to submit a renewed discovery schedule if the case has not settled. Signed by Magistrate Judge Peggy A. Leen on 2/8/2018. (Copies have been distributed pursuant to the NEF - MR)

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MORRIS LAW CENTER
SARAH A. MORRIS, ESQ.
Nevada Bar No. 8461
[e-mail]
TIMOTHY A. WISEMAN, ESQ.
Nevada Bar No. 13786
[e-mail]
5450 W. Sahara Ave, Suite 330
Las Vegas, Nevada 89146
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendants, Premier One Holdings, Inc.,
Mimi Ventures LLC, and Eric M. Chen

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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DEUTSCHE BANK NATIONAL TRUST
COMPANY, as trustee for Washington
Mutual
Mortgage
Pass-Through
Certificates Series 2004-AR10;

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Case No.: 2:16-cv-02805-JCM-PAL

Plaintiff,
vs.
PREMIER
ONE
HOLDINGS,
INC.;
ANTHEM
COUNTRY
CLUB
ASSOCIATION, INC. ; MIMI VENTURES
LLC ; ERIC M. CHEN;
Defendants,
AND ALL RELATED MATTERS.
STIPULATION AND ORDER TO STAY DISCOVERY
Defendants, Premier One Holdings, Inc. (“Premier”), Mimi Ventures, LLC
(“Mimi”), and Eric M. Chen (“Chen”) by and through Sarah A. Morris, Esq. and
Timothy A. Wiseman, Esq. of the law firm Morris Law Center; Deutsche Bank National
Trust Company, As trustee for Washington Mutual Mortgage Pass-Through
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Certificated Series 2004-AR10 (“Plaintiff”) by and through Sylvia O. Semper, Esq. of the

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law firm Ballard Spahr; Defendant, Anthem Country Association Club, Inc., by and

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through Julie Funai, Esq., of Lipson Neilson Cole Seltzer & Garin, P.C., hereby agree

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and stipulate as follows:

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IT IS HEREBY AGREED AND STIPULATED, that the parties jointly request an

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Order staying all discovery for 90 days as the parties are conducting settlement

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discussions and hope to settle this case.

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The parties have good cause for requesting the stay due to ongoing settlement

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negotiations. The parties believe a stay of the matter to be appropriate to conserve

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judicial resources. The parties have entered into the agreement in good faith and not for

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purposes of delay.
IT IS FURTHER AGREED AND STIPULATED that once the stay is lifted, any
remaining parties will submit a renewed discovery schedule 30-days from the date the
stay is lifted.

Dated: January 5, 2018

Dated: January 10, 2018

MORRIS LAW CENTER

BALLARD SPAHR LLP

By:/s/ Timothy A. Wiseman
Sarah A. Morris, Esq.
Nevada Bar No. 8461
Timothy A. Wiseman, Esq.
Nevada Bar No. 13786
Attorneys for Defendant, Premier One
Holdings, Inc., Mimi Ventures LLC,
and Eric M. Chen.

By: /s/ Scott A. Wiseman_____
Abran E. Vigil, Esq.
Nevada Bar No. 7548
Sylvia O. Semper, Esq.
Nevada Bar No. 12863
Attorneys for Plaintiff

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Dated: January 10, 2018

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LIPSON NEILSON COLE SELTZER
& GARIN, P.C.

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By:/s/ Julie Funai_______
Julie Funai, Esq.
Nevada Bar No. 8725
9900 Covington Cross Drive, Suite
120, Las Vegas, NV 89144
Attorneys for Anthem Country
Association Club, Inc

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ORDER
IT IS ORDERED that this case is stayed for 90 days, or until April 12, 2018.
IT IS SO ORDERED this
day of
IT IS FURTHER ORDERED that the parties shall have until May 14, 2018, to
submit a renewed discovery schedule if the case has not settled.
Dated: February 8, 2017

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UNITED STATES MAGISTRATE JUDGE

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Respectfully submitted:

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By:/s/ Timothy A. Wiseman
Timothy A. Wiseman
Nevada Bar No. 13786
Attorneys for Defendant, Premier One
Holdings, Inc., Mimi Ventures LLC,
and Eric M. Chen.

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CERTIFICATE OF SERVICE

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I, the undersigned, declare under penalty of perjury, that I am over the age of

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eighteen (18) years, and I am not a party to, nor interested in, this action. On this date, I
caused to be served a true and correct copy of the foregoing STIPULATION AND
ORDER TO STAY DISCOVERY by the method indicated:

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BY FAX: by transmitting via facsimile the document(s) listed above to the
fax number(s) set forth below on this date before 5:00 p.m. pursuant to
EDCR Rule 7.26(a). A printed transmission record is attached to the file copy
of this document(s).

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BY E-MAIL: by transmitting via e-mail the document(s) listed above to the
email addresses set forth below and/or included on the Court's Service List
for the above-referenced case.

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BY U.S. MAIL: by placing the document(s) listed above in a sealed envelope
with postage thereon fully prepaid, in the United States mail at Las Vegas,
Nevada addressed as set forth below.

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BY OVERNIGHT MAIL: by causing document(s) to be picked up by an
overnight delivery service company for delivery to the addressee(s) on the
next business day.

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BY PERSONAL DELIVERY: by causing personal delivery via messenger
service of the document(s) listed above to the person(s) at the address(es)
set forth below.

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BY ELECTRONIC SUBMISSION: submitted to the above-entitled Court
for electronic filing and service upon the Court's Service List for the abovereferenced case.
and addressed to the following:

Lipson Neilson Cole Seltzer & Garin, P.C.
Julie Funai [e-mail]
Ballard Sphar LLP
Sylvia O. Semper [e-mail]
Joel Edward Tasca [e-mail]
Abran A. Vigil [e-mail]
Dated this 9th day of January, 2018.
An employee of Morris Law Center

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