Wells Fargo Bank, N.A. v. Saticoy Bay LLC Series 3948 Applecrest et al

Filing 30

ORDER Granting 29 Stipulation for Extension of Time to Amend Pleadings and Add Parties (First Request). Signed by Magistrate Judge Cam Ferenbach on 5/10/2019. (Copies have been distributed pursuant to the NEF - MR)

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Richard C. Gordon
Nevada Bar No. 9036
Tanya N. Lewis
Nevada Bar No. 8855
SNELL & WILMER L.L.P.
3883 Howard Hughes Parkway
Suite 1100
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: 702.784.5252
Email: [e-mail]
[e-mail]
Attorneys for Plaintiff Wells Fargo Bank, N.A.
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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WELLS FARGO BANK, N.A.,
Plaintiff,
vs.
SATICOY BAY LLC – SERIES 3948
APPLECREST, a Nevada limited-liability
company; WOODCREST HOMEOWNERS
ASSOCIATION; a Nevada non-profit
corporation; ABSOLUTE COLLECTION
SERVICES, LLC, a Nevada limited-liability
company; DOES 1 through 10; and ROE
BUSINESS ENTITIES 1 through 10, inclusive,

Case No. 2:17-cv-1360-APG-VCF
STIPULATION AND ORDER TO
EXTEND DEADLINE TO AMEND
PLEADINGS AND ADD PARTIES
(First Requested Extension After Lift of
Stay)

Defendants.

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Pursuant to Local Rules 6-1 and 26-4, the parties stipulate, and request that the Court
approve, a fourteen-day extension of the deadline to amend pleadings and add parties from May
14, 2019 to May 28, 2019. The parties do not seek any other extension of the existing case deadlines
at this time. Wells Fargo is still reviewing information related to the possible elimination and
substitution of claims and needs a brief, two-week extension to finalize and file its Amended
Complaint. This is the first request (post lift of stay) for an extension of deadlines contained within
the discovery plan and scheduling order.

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This request comes less than twenty-one days before expiration of the current deadline to

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amend pleadings, and, therefore, must be supported by good cause. Good cause exists to extend the

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deadline here, as the parties are currently conducting discovery and locating the information needed

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to finalize their amended pleadings, but need a brief extension to confirm additional information

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regarding their claims.

completion of discovery in this matter. The request for additional time at this point reflects the

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need for the parties to plan strategically based on the full factual and legal record -- not any dilatory

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conduct by any party. The stipulated extension will also eliminate the need for expensive, time-

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consuming motions for both the parties and the court. No prejudice will result from the requested

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Snell & Wilmer

The parties are amicably, professionally, diligently, and in good faith working toward the

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L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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extension, as the parties currently anticipate that they will be able to complete discovery on or

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before the August 2019 deadline.

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For these reasons, and based on the circumstances, the parties request an extension of the
dispositive motions deadlines and subsequent deadlines as follows:
This stipulated request is submitted in good faith for the reasons explained above, and not
for purposes of undue delay.

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Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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Dated: May 9, 2019
LAW OFFICES OF MICHAEL F. BOHN, ESQ., LTD.

SNELL & WILMER L.L.P.

/s/ Nikoll Nikci
Michael F. Bohn
Adam R. Trippiedi
Nikoll Nikci
2260 Corporate Circle, Suite 480
Henderson, NV 89074
[e-mail]
[e-mail]
[e-mail]

/s/ Tanya N. Lewis
.
Richard C. Gordon
Tanya N. Lewis
3883 Howard Hughes Parkway
Suite 1100
Las Vegas, Nevada 89169

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Attorneys for Plaintiff Wells Fargo Bank,
N.A.

Attorneys for Defendant Saticoy Bay LLC Series
3948 Applecrest
*e-signature affixed with permission
HOA LAWYERS GROUP, LLC

ABSOLUTE COLLECTION SERVICES, LLC

/s/ Steven T. Loizzi, Jr
.
Steven T. Loizzi , Jr.
9500 West Flamingo Road, Suite 204
Las Vegas, NV 89147-572
[e-mail]

/s/ Shane D. Cox
.
Shane D. Cox
7485 W. Azure Dr., Suite 129
Las Vegas, NV 89130
[e-mail]

Attorneys for Defendant Woodcrest
Homeowners Association

Attorney for Defendant Absolute Collection
Services, LLC

*e-signature affixed with permission

*e-signature affixed with permission

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SCHEDULING ORDER
The deadline to amend pleadings and add parties is hereby extended from May 14, 2019
to May 28, 2019. All other current deadlines remain in effect.
IT IS SO ORDERED.
______________________________________
United States Magistrate Judge
5-10-2019
Dated: _______________________________

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CERTIFICATE OF SERVICE

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I hereby certify that on this date, I electronically transmitted the foregoing STIPULATION

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AND ORDER TO EXTEND DEADLINE TO AMEND PLEADINGS AND ADD PARTIES

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with the Clerk of Court for the U.S. District Court, District of Nevada by using the CM/ECF system

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for filing and transmittal of a Notice of Electronic Filing to all counsel in this matter; all counsel

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being registered to receive Electronic Filing.

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DATED: May 9, 2019

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/s/ Susan Ballif
An employee of SNELL & WILMER L.L.P.
4819-1705-3078

Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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