KK Real Estate Investment Fund, LLC v. Deutsche Bank Trust Company et al

Filing 15

ORDER Granting 14 Stipulation for Extension of Time re 13 Motion to Dismiss (First Request). Responses due by 10/16/2017. Replies due by 10/21/2017. Signed by Chief Judge Gloria M. Navarro on 10/5/17. (Copies have been distributed pursuant to the NEF - MR)

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LUIS A. AYON, ESQ.
Nevada Bar No. 9752
AYON LAW, PLLC
9205 West Russell Road
Building 3, Suite 240
Las Vegas, Nevada 89148
Telephone:
[phone]
Facsimile:
[phone]
E-Mail:
[e-mail]
Attorneys for Plaintiff,
KK Real Estate Investment Fund, LLC

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UNITED STATES DISTRICT COURT
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FOR THE DISTRICT OF NEVADA

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KK REAL ESTATE INVESTMENT Case No.: 2:17-cv-01040-GMN-GWF
FUND, LLC., a Nevada limited liability
company;
STIPULATION TO EXTEND TIME TO
RESPOND TO DEFENDANT DEUTSCHE
Plaintiffs,
BANK TRUST COMPANY AND WESTERN
vs.
PROGRESSIVE-NEVADA, INC.’S MOTION
TO DISMISS
DEUTSCHE BANK TRUST COMPANY
AMERICAS,
AS
TRUSTEE
FOR (First Request)
RESIDENTIAL ACCREDIT LOANS,
INC., MORTGAGE ASSET-BACKED
PASS-THROUGH
CERTIFICATES,
SERIES
2007-QS2;
WESTERN
PROGRESSIVE NEVADA, INC., a
Delaware corporation registered with the
Nevada Secrertary of State; NEVADA
ASSOCIATION SERVICES,
Defendants.

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IT IS HEREBY STIPULATED by and between Plaintiff KK REAL ESTATE
INVESTMENT FUND, LLC, a Nevada limited liability company (hereinafter “KK Real Estate”) and
Defendants, DEUTSCHE BANK TRUST COMPANY AMERICAS, AS TRUSTEE FOR
RESIDENTIAL ACCREDIT LOANS, INC., MORTGAGE ASSET-BACKED PASS-THROUGH
SERIES

(“Deutsche

2007-QS2

Bank”),

and

WESTERN

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CERTIFICATES,

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PROGRESSIVE-NEVADA, INC., a Delaware corporation registered with the Nevada Secretary of
State (“Western”) (hereinafter KK Real Estate, Deutsche Bank Trust Company and Western

AYON LAW, PLLC
9205 W. Russell Road,
Building 3, Suite 240
LAS VEGAS, NEVADA 89148
PHONE: [phone]

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Progressive Nevada, Inc. shall be referred to collectively as the “Parties”) through their respective
counsel of record as follows:
WHEREAS, Deutsche Bank and Western filed and served KK Real Estate with its Motion to
Dismiss on September 18, 2017.
WHEREAS, KK Real Estate’s Opposition to the Motion is due to be filed and served on
October 2, 2017.
WHEREAS, settlement discussions began in this case in August of 2017.
WHEREAS, Parties need more time to discuss potential settlement and/or respond to said
pending motion.

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WHEREAS, The Parties stipulate as follows:
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IT IS HEREBY AGREED AND STIPULATED between the Parties, by and through their
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undersigned attorneys, that KK Real Estate shall have up to and including October 16, 2017 to file its
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Opposition to the Motion.
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IT IS HEREBY AGREED AND STIPULATED between the Parties, by and through their
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undersigned attorneys, that Deutsche and Western shall have up to and including October 21, 2017 to
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file its Reply in Support of its Motion to Dismiss.
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This is the Parties first request for an extension of time to file the Opposition to the Motion, and
is not intended to cause any delay or prejudice to any Party.
Approved as to Form and Content:

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DATED this 5th day of October, 2017.

DATED this 5th day of October, 2017.

AYON LAW, PLLC

WRIGHT, FINLAY & ZAK, LLP

_/s/ Luis A. Ayon________
LUIS A. AYON, ESQ.
Nevada Bar No. 9752
9205 W. Russell Road
Building 3, Suite 240
Las Vegas, Nevada 89148

_/s/Patrick J. Davis____________
PATRICK J. DAVIS, ESQ.
Nevada Bar No. 13330
7785 W. Sahara Avenue, Suite 200
Las Vegas, Nevada 89117

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AYON LAW, PLLC
9205 W. Russell Road,
Building 3, Suite 240
LAS VEGAS, NEVADA 89148
PHONE: [phone]

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ORDER
Pursuant to the above Stipulation of the Parties, it is ORDERED that:
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KK Real Estate shall have up to and including October 16, 2017 to file it Opposition
to the Motion.

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Deutsche and Western shall have up to and including October 21, 2017 to file its
Reply in Support of the Motion to Dismiss.

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October
DATED this _____ day of __________________, 2017.
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_________________________________________
DISTRICT COURT JUDGE

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AYON LAW, PLLC
9205 W. Russell Road,
Building 3, Suite 240
LAS VEGAS, NEVADA 89148
PHONE: [phone]

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