United States of America et al v. Bank of George et al

Filing 63

ORDER Granting 62 Stipulation to Extend Deadline for Counterdefendant to File a Reply Brief to Counterclaimant's Opposition to Counterdefendant's Special Motion to Dismiss. Reply brief due by 6/22/2021. Signed by Magistrate Judge Elayna J. Youchah on 6/7/2021. (Copies have been distributed pursuant to the NEF - YAW)

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LAGOMARSINO LAW
ANDRE M. LAGOMARSINO, ESQ.
Nevada Bar No. 6711
3005 W. Horizon Ridge Pkwy., # 241
Henderson, Nevada 89052
Telephone: [phone]
Facsimile: [phone]
Attorney for Plaintiff Steven Trang

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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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STEVEN TRANG, an individual,

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Case No.: 2:17-cv-00162-APG-EJY

Plaintiff,

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vs.
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BANK OF GEORGE, a Domestic
Corporation; and T. RYAN SULLIVAN in
his individual and professional capacity,

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Defendants.

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STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINE FOR
COUNTERDEFENDANT TO FILE A REPLY
BRIEF TO COUNTERCLAIMANT’S
OPPOSITION TO COUNTERDEFENDANT’S
SPECIAL MOTION TO DISMISS
(First Request)

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Pursuant to LR IA 6-1, 6-2, Plaintiff/Counterdefendant STEVEN TRANG, by and through his

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attorney of record, Andre Lagomarsino, Esq. of Lagomarsino Law and Defendants/Counterclaimants

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LAGOMARSINO LAW

3005 West Horizon Ridge Parkway, Suite 241 • Henderson, Nevada 89052
Telephone [phone] Facsimile [phone]

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BANK OF GEORGE and T. RYAN SULLIVAN by and through their attorney of record, Richard I.
Dreitzer, Esq. of the law firm of Fennemore Craig, P.C. hereby stipulate to extend the deadline for
Counterdefendant to file a Reply to Counterclaimant’s Opposition to Counterdefendant’s Special

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Motion to Dismiss (ECF No. 61). Counterdefendant filed his Special Motion to Dismiss
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Counterclaimant’s Counterclaim (ECF No. 55) on April 19, 2021. Pursuant to stipulation,

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Counterclaimant filed its Opposition to Counterdefendant’s Special Motion to Dismiss on May 31,

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2021. (ECF No. 61). The Reply brief is currently due June 8, 2021.

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This is the first request for an extension to file a Reply brief.

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The reason for the extension is that Counterdefendant’s counsel has only one (1) attorney

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currently on the case and that attorney was briefing three (3) other voluminous briefs in two (2)

counsel (the aforementioned attorney) worked all three (3) days of the Memorial Day weekend and

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all of the following week in an effort to get caught up to the Reply brief but was unsuccessful.

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The following week, the Counterdefendant’s counsel and the other attorney in his firm will be

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in depositions and preparing for depositions in other important and large damage matters and will be
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precluded from devoting adequate time to the Reply brief. While the undersigned has enlisted a law

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clerk to assist, counsel will still need time to review, research, edit and finalize the Reply brief so that

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it is of the quality that is expected in United States District Court.

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LAGOMARSINO LAW

different cases during the time that was allotted to file a Reply brief in this case. The undersigned

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3005 West Horizon Ridge Parkway, Suite 241 • Henderson, Nevada 89052
Telephone [phone] Facsimile [phone]

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The parties agree, subject to the Court’s approval, that the new deadline to file a Reply

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brief will be June 22, 2021. The requested extension is sought in good faith and not for purposes of

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undue delay.
IT IS SO STIPULATED.

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Dated this 4th day of June, 2021.

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LAGOMARSINO LAW FIRM

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By:
/s/ Andre M. Lagomarsino
ANDRE M. LAGOMARSINO, ESQ.
Nevada Bar No. 6711
3005 West Horizon Ridge Pkwy, #241
Henderson, Nevada 89052
Telephone: [phone]
[e-mail]
Attorneys for Plaintiff/Counterdefendant TRANG

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IT IS SO ORDERED.

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By:

_______________________________________
UNITED STATES MAGISTRATE JUDGE

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LAGOMARSINO LAW

FENNEMORE CRAIG, P.C.
By: /s/ Richard I. Dreitzer _______
RICHARD I. DREITZER, ESQ.
NV Bar No. 6626
300 South Fourth Street, Suite 1400
Las Vegas, Nevada 89101
Telephone: [phone]
[e-mail]
Attorneys for Defendants/Counterclaimants BANK OF GEORGE and SULLIVAN

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3005 West Horizon Ridge Parkway, Suite 241 • Henderson, Nevada 89052
Telephone [phone] Facsimile [phone]

DATED: this 4th day of June, 2021.

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Dated: June 7, 2021

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