Board of Trustees of the Plumbers and Pipefitters Union Local 525 Pension Plan v. Blevins et al

Filing 43

ORDER Granting 42 Stipulation to Extend Time Re: 38 Motion to Dismiss, 35 Motion to Quash. IT IS SO ORDERED that the Trust's responses to the PBS's Motion to Dismiss and Motion to Quash Summons are due 11/29/17, and PBS's replies in support to the Motions are due 12/6/17. Signed by Judge Richard F. Boulware, II on 11/16/2017. (Copies have been distributed pursuant to the NEF - ADR)

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Adam P. Segal, Esq.
Nevada Bar No. 6120
Bryce C. Loveland, Esq.
Nevada Bar No. 10132
BROWNSTEIN HYATT FARBER SCHRECK, LLP
100 North City Parkway, Suite 1600
Las Vegas, Nevada 89106-4614
Telephone: [phone]
Facsimile: 702.382.8135
Email: [e-mail]
Email: [e-mail]

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Attorneys for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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100 NORTH CITY PARKWAY, SUITE 1600
LAS VEGAS, NV 89106
[phone]

BROWNSTEIN HYATT FARBER SCHRECK, LLP

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v.

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Defendants.
Plaintiff, the Board of Trustees of the Plumbers and Pipefitters Union Local 525 Pension
Plan (the “Trust”) and Defendant The Peoples State Bank (“PSB”) by and through their
undersigned counsel of record, stipulate and request an order extending the Trust’s response
deadline to PSB’s Motion to Dismiss [ECF No. 38, filed November 1, 2017] by 14 (fourteen)
days from November 15, 2017, to November 29, 2017. The parties also stipulate and request that
PSB’s reply in support of its Motion to Dismiss be due on December 6, 2017.
The parties also stipulate and request an order extending the Trust’s response deadline to

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[FIRST REQUEST]

TAMARA L. BLEVINS, as an individual;
TAMARA L. BLEVINS, as the CourtAppointed Personal Representative of the
Estate of Lawrence R. Brosi; ZENITH
AMERICAN SOLUTIONS, INC., a Maryland
corporation; THE PEOPLES STATE BANK,
an Indiana corporation,

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STIPULATION AND ORDER TO
EXTEND RESPONSE DEADLINES

Plaintiff,

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CASE NO.: 2:17-CV-01223-RFB-NJK

BOARD OF TRUSTEES OF THE
PLUMBERS AND PIPEFITTERS UNION
LOCAL 525 PENSION PLAN,

PSB’s Motion to Quash Summons [ECF No. 35, filed October 30, 2017] by sixteen (16) days

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16145871

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from November 13, 2017, to November 29, 2017. The parties also stipulate and request that
PSB’s reply in support of its Motion to Quash Summons be due on December 6, 2017.

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100 NORTH CITY PARKWAY, SUITE 1600
LAS VEGAS, NV 89106
[phone]

BROWNSTEIN HYATT FARBER SCHRECK, LLP

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The motions filed on October 30, 2017 [ECF 35] and November 1, 2017 [ECF 38] are
identical. Based on the Court’s Notice of Non Compliance with LR IC 2-2 and FRCP 7 [ECF
No. 37], the Trust’s counsel was under the impression that both the Motion to Quash Summons
and Motion to Dismiss were considered filed on November 1, 2017, and calculated that
responsive pleading to both the Motion to Quash and the Motion to Dismiss as being due on
November 15, 2017. It has now come to the Trust counsel’s attention that the Motion to Quash
Summons may have been considered filed on October 30, 2017, and that a responsive pleading
would have been due on November 13, 2017. Because both the Motion to Quash Summons and
the Motion to Dismiss request substantially the same relief, an extension to respond to the Motion
to Quash Summons will not cause undue delay or inefficiency.
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16145871

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The pending extension request will have no prejudice on the pending discovery cutoff
deadlines and is not sought for an improper purpose or delay.

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KAEMPFER CROWELL

/s/ Bryce C. Loveland
Adam P. Segal, Esq.
Nevada Bar No. 6120
Bryce C. Loveland, Esq.
Nevada Bar No. 10132
100 North City Parkway, Suite 1600
Las Vegas, Nevada 89106-4614
Telephone: [phone]
Facsimile: [phone]

/s/ Joni Jamison
Robert McCoy, Esq.
Nevada Bar No. 9121
Joni A. Jamison, Esq.
Nevada Bar No. 11614
1980 Festival Plaza Drive, Suite 650
Las Vegas, Nevada 89135
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant, The Peoples State
Bank

Dated: November 15, 2017

Dated: November 15, 2017

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100 NORTH CITY PARKWAY, SUITE 1600
LAS VEGAS, NV 89106
[phone]

BROWNSTEIN HYATT FARBER SCHRECK, LLP

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BROWNSTEIN HYATT FARBER
SCHRECK, LLP

Attorneys for Plaintiff

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ORDER

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IT IS SO ORDERED that the Trust’s responses to the PBS’s Motion to Dismiss and

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Motion to Quash Summons are due November 29, 2017, and PBS’s replies in support to the
Motions are due December 6, 2017.

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________________________________________________
UNITED STATES DISTRICT/MAGISTRATE JUDGE

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CASE NO: 2:17-CV-01223-RFB-NJK

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November 16, 2017.
DATED: _______________________________________

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16145871

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