Agha-Khan v. Wells Fargo Bank NA A US Bank et al

Filing 88

ORDER Granting 86 Motion to Extend Time. Navy Federal Credit Union answer due 6/1/2017. Signed by Magistrate Judge Peggy A. Leen on 5/30/17. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-02928-APG-PAL Document 86 Filed 05/22/17 Page 1 of 4

1
2
3
4
5
6
7

Zachary T. Ball, Esq.
Nevada Bar No. 8364
THE BALL LAW GROUP
3455 Cliff Shadows Parkway
Suite 150
Las Vegas, Nevada 89129
Telephone: [phone]
Email: [e-mail]
Attorney for Navy Federal
Credit Union, Jeffrey L. Romig and
Patricia Romig (formally known as
Patricia Krause)

8

UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10

SALMA AGHA-KHAN, MD., an individual

12
vs.

14

WELLS FARGO BANK, NA, a US Bank;
WELLS FARGO FINANCIAL NATIONAL
BANK, a National Banking Association;
WELLS FARGO HOME MORTGAGE, a
Wells Fargo Bank, NA subsidiary;
MORTGAGE ELECTRONIC
REGISTRATION SYSTEMS, INC., a
Delaware agency/corporation, form
unknown; MERSCORP HOLDINGS INC,
holding/parent company of MERS Inc.; TBI
MORTGAGE COMPANY, a mortgage
company; GMAC MORTGAGE, LLC FKA
GMAC MORTGAGE CORPORATION, a
financial lending business; OCWEN
FINANICAL CORPORATION, a financial
concern, form unknown; MARTIN
CONVEYANCING CORP AKA MARTIN
CONVEYANCING CORPORATION, a
lending corporation form unknown;
EXECUTIVE TRUSTEE SERVICES, LLC,
a defunct Delaware company form unknown;
FIRST AMERICAN TITLE COMPANY, a
title agency form unknown; FIRST
AMERICAN TITLE INSURANCE
COMPANY, a title insurance company form
unknown; ROUTH CRABTREE OLSEN PS,
a law firm in California; EDWARD T.
WEBER, an individual and attorney at Routh
Crabtree Olsen, PS; BRETT P. RYAN, an

15
16
17
18
19
20
21
22
23
24
25
26
27
28

Case No.: 2:16-CV-02928-APG-PAL

Plaintiff,

13
[phone]

Las Vegas, Nevada 89129

3455 Cliff Shadows Parkway, Suite 150

THE BALL LAW GROUP

11

MOTION TO EXTEND TIME TO
RESPOND TO COUNTERCLAIM

PAGE 1 OF 4

Case 2:16-cv-02928-APG-PAL Document 86 Filed 05/22/17 Page 2 of 4

1
2
3
4
5
6
7
8
9
10

12
13
[phone]

Las Vegas, Nevada 89129

3455 Cliff Shadows Parkway, Suite 150

THE BALL LAW GROUP

11

14
15
16
17

individual and attorney at Routh Crabtree
Olsen, PS; JOHNATHAN J. DAMEN, an
individual and attorney at Routh Crabtree
Olsen, PS; JEFF ROMIG AKA JEFFREY L.
ROMIG, an individual; PATRICIA J.
KRAUSE, an individual; GREENPOINT
MORTGAGE FUNDING, INC, a mortgage
company form unknown; SERVICELINK
AKA SERVICELINK, LLC a business
organization form unknown; LSI TITLE
AGENCY INC, a title agency form
unknown; CHICAGO TITLE COMPANY, a
title company form unknown; FIDELITY
NATIONAL DEFAULT SOLUTIONS INC,
a company form unknown; NATIONWIDE
TITLE CLEARING, a title company form
unknown, AMANDA ROSE JONES, an
individual and Assistant Secretary for MERS
Inc; KRISTOPHER JAMES SANBERG, a
Wells Fargo employee; AND DOES 1
THROUGH 1000 INCLUSIVE,
Defendants.
Pursuant to Federal Rule of Civil Procedure 6(b), Defendant-Intervenor NAVY FEDERAL
CREDIT UNION (“Navy Federal”), by and through its attorney, Zachary T. Ball, Esq. of Ball
Law Group, hereby requests an Order granting additional time, up to June 1, 2017 (10 days from
the date of this Motion) to file a responsive pleading to Plaintiff/Counterclaimant SALMA

18

AGHA-KHAN, M.D.’S (“Plaintiff/Counterclaimant”) Counterclaim to NAVY FEDERAL’S

19

Complaint in Intervention [Document #82].

20
21
22
23
24
25
26

DATED this 22nd day of May, 2017.
THE BALL LAW GROUP
/s/ Zachary T. Ball, Esq.
Zachary T. Ball, Esq., NBN 8364
3455 Cliff Shadows Pkwy., Suite 150
Las Vegas, Nevada 89129
Attorney for Navy Federal
Credit Union, Jeffrey L. Romig and
Patricia Romig (formally known as
Patricia Krause)

27
28
PAGE 2 OF 4

Case 2:16-cv-02928-APG-PAL Document 86 Filed 05/22/17 Page 3 of 4

1
2

POINTS AND AUTHORITIES
Plaintiff/Counterclaimant’s initial Complaint was filed on December 16, 2016, by filing

3

his in proper person Complaint [Document #1] which spans 75 pages, asserts 16 causes of

4

action, and includes 236 separate factual allegations that require individual responses.

5
6

Navy Federal, the moving party, filed a Complaint in Intervention to which Plaintiff/
Counterclaimant answered and filed a Counterclaim against Nevada Federal on or about May

7
8
9

1, 2017 [Document #82]. This document contains an Answer to Navy Federal’s Complaint in
Intervention as well as a Counterclaim, the latter of which is 23 pages long (not including

length of the pleading to 68 pages). It multiple causes of action and contains 93 paragraphs

12

which require individual responses.

13
[phone]

Las Vegas, Nevada 89129

3455 Cliff Shadows Parkway, Suite 150

exhibits, the Answer, and the declaration of Plaintiff/Counterclaim, which bring the total

11
THE BALL LAW GROUP

10

14
15
16

It is this pleading (i.e. Plaintiff/Counterclaimant’s Counterclaim against Nevada Federal
[Document #82]) which is at issue in this Motion. A responsive pleading to said Counterclaim
is due on the date of this filing (May 22, 2017). By way of this Motion, Navy Federal seeks a

17

brief 10-day extension (which, by Navy Federal’s calculation, is June 1, 2017) to file said

18

responsive pleading. This request is made pursuant to F.R.C.P. 6(b)(1)(A) as Navy Federal’s

19

time period to respond to the Counterclaim has not yet passed.

20
21
22
23
24
25
26
27
28

Good cause exists to extend the time to respond to the Counterclaim because the length
of the 68-page pleading (including exhibits), the complexity presented in the causes of action
and the 93 paragraphs of factual allegations and prayers for relief, and the investigation and
research that will be necessary to respond to all. The requested time is needed to investigate
the facts and analyze the applicable law in order to prepare an appropriate response.
Moreover, it is unlikely Plaintiff/Counterclaimant will be prejudiced in any way by the
minimal amount of time (10 days) Navy Federal is requesting to respond. This is a very short
amount of time and will not impact the matter in any way.
PAGE 3 OF 4

Case 2:16-cv-02928-APG-PAL Document 86 Filed 05/22/17 Page 4 of 4

CONCLUSION

1
2
3
4

For these reasons, Navy Federal respectfully requests an extension of time to respond to
Plaintiff/Counterclaimant’s Counterclaim until June 1, 2017.
DATED this 22nd day of May, 2017.
THE BALL LAW GROUP

5
6
7
8
9
10

IT IS SO ORDERED this 30th day of
May, 2017.

_____________________________
Peggy A. Leen
United States Magistrate Judge

/s/ Zachary T. Ball, Esq.
Zachary T. Ball, Esq., NBN 8364
3455 Cliff Shadows Pkwy., Suite 150
Las Vegas, Nevada 89129
Attorney for Navy Federal
Credit Union, Jeffrey L. Romig and
Patricia Romig (formally known as
Patricia Krause)

12
13
[phone]

Las Vegas, Nevada 89129

3455 Cliff Shadows Parkway, Suite 150

THE BALL LAW GROUP

11

CERTIFICATE OF SERVICE

14
15

The undersigned employee of THE BALL LAW GROUP hereby certifies that the

16

foregoing MOTION TO EXTEND TIME TO RESPOND TO COMPLAINT was

17

electronically filed with the United States District Court on the 22nd day of May, 2017. Service

18

of the foregoing document was made to all parties and counsel as identified on the Court-

19

generated Notice of Electronic Filing and/or by depositing a true and correct copy of the same

20

to the addresses shown below and by U.S. Mail, with first class postage prepaid there in a sealed

21

envelope addressed to the following:

22

Salma Agha-Khan
3751 Motor Ave #34272
Los Angeles, CA 90034
Pro Se

23
24
25
26

/s/ Zachary T. Ball, Esq.
An Employee of the Ball Law Group

27
28
PAGE 4 OF 4