1st One Hundred Investment Pool, LLC v. Rose et al

Filing 4

ORDER Granting 3 Stipulation Extending Deadlines. Bank of New York Mellon Trust Company answer due 5/23/2017. Motions due by 6/15/2017.) Signed by Magistrate Judge Peggy A. Leen on 5/11/17. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-01233-JCM-PAL Document 3 Filed 05/09/17 Page 1 of 3

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WRIGHT, FINLAY & ZAK, LLP
Dana Jonathon Nitz, Esq.
Nevada Bar No. 50
Patrick J. Davis, Esq.
Nevada Bar No. 13330
7785 W. Sahara Avenue, Suite 200
Las Vegas, NV 89117
[phone]; Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant The Bank of New York Mellon Trust Company, National Association
fka The Bank of New York Trust Company, N.A. as successor to JP Morgan Chase Bank, as
Trustee for Residential Asset Mortgage Products, Inc.

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IN THE UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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1st ONE HUNDRED INVESTMENT POOL,
LLC, a Nevada limited liability company,
Plaintiff,

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vs.
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CARMEN J. ROSE; MORTGAGE
ELECTRONIC REGISTRATION
SYSTEMS, INC.; CAPITOL COMMERCE
MORTGAGE COMPANY; THE BANK OF
NEW YORK MELLON TRUST
COMPANY, NATIONAL ASSOCIATION,
fka THE BANK OF NEW YORK TRUST
COMPANY N.A. as successor the JP
MORGAN CHASE BANK, as Trustee for
RESIDENTIAL ASSET MORTGAGE
PRODUCTS, INC.; SABLES, LLC; TAL
ZISSU; THE 12017 OAKLAND HILLS
DRIVE IRREVOCABLE TRUST; TAL
XAVIER TRUST; XAVIER REYES;
FASHION SHOW MALL, LLC; STATE OF
NEVADA; SCOT OLIPHANT, AND DOES I
through X, inclusive; and ROE
CORPORATIONS I through X, inclusive,

Case No.: 2:17-cv-01233-JCM-PAL

STIPULATION AND ORDER FOR STAY
AND EXTENDING DEADLINE FOR
DEFENDANT BNY TO ANSWER THE
COMPLAINT AND FOR PLAINTIFF TO
FILE A MOTION FOR REMAND

First Request

Defendants.

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Page 1 of 3

Case 2:17-cv-01233-JCM-PAL Document 3 Filed 05/09/17 Page 2 of 3

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Defendant The Bank of New York Mellon Trust Company, National Association, f/k/a

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The Bank of New York Trust Company N.A. as successor the JP Morgan Chase Bank, as

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Trustee for Residential Asset Mortgage Products, Inc. (“BNY”) and Plaintiff, 1st One Hundred

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Investment Pool, LLC (“Plaintiff), by and through their respective counsel of record, stipulate

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and agree to extend the time for BNY to file an Answer and for Plaintiff to file a Motion for

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Remand by 10 judicial days each, respectively in order to discuss potential settlement and proper

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forum of the case.

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The current dates for filing an Answer and Motion for Remand are May 9, 2017 and June

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1, 2017 respectively. The new deadline to Answer shall be May 23, 2017. The new deadline to

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file a Motion for Remand shall be June 15, 2017.

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Case 2:17-cv-01233-JCM-PAL Document 3 Filed 05/09/17 Page 3 of 3

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This Stipulation is reached in good faith and not for purpose of delay.

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IT IS SO STIPULATED.

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DATED this 9th day of May, 2017

DATED this 9th day of May, 2017

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WRIGHT, FINLAY & ZAK, LLP

The Law Office of Vernon Nelson

/s/Patrick J. Davis____________________
Dana Jonathon Nitz, Esq.
Nevada Bar No. 0050
Natalie C. Lehman, Esq.
Nevada Bar No. 12995
Patrick J. Davis, Esq.
Nevada Bar No. 13330
7785 W. Sahara Ave., Suite 200
Las Vegas, NV 89117
[phone]; Fax: [phone]
[e-mail]
Attorney for Defendants, The Bank of New
York Mellon Trust Company, National
Association fka The Bank of New York Trust
Company, N.A. as successor to JP Morgan
Chase Bank, as Trustee for Residential
Asset Mortgage Products, Inc.

_/s/Vernon A. Nelson, Esq._____________
Vernon A. Nelson, Jr., Esq.
9480 S. Eastern Ave., Ste. 244
Las Vegas, NV 89123
Attorney for Plaintiff, 1st One Hundred
Investment Pool, LLC

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ORDER

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IT IS SO ORDERED.

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_______________________________________
UNITED STATES MAGISTRATE JUDGE
May 11, 2017
Dated: _________________________________

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