Gryglak v. HSBC Bank USA, N.A., et al

Filing 42

ORDER Granting 39 First Stipulation re Deposition and Extending Deadline for Dispositive Motion and Pretrial Order. The deposition of plaintiff Edyta Gryglak is permitted to proceed on 8/17/2018. Motions due by 9/13/2018. Proposed Joint Pretrial Order due by 10/16/2018. Signed by Magistrate Judge Nancy J. Koppe on 7/12/2018. (Copies have been distributed pursuant to the NEF - SLD)

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VEGAS WEST ATTORNEYS
Boris Avramski, Esq.
Nevada Bar No. 11350
5594 South Fort Apache Road, Suite 120
Las Vegas, NV 89148
Phone: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiff

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
EDYTA GRYGLAK, formerly known
as EDYTA A. FROMKIN,

)
)
)
Plaintiff,
)
vs.
)
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HSBC BANK USA, N.A., as trustee for
)
WELLS FARGO HOME EQUITY ASSET- )
BACKED CERTIFICATES, Series 2006-3, by )
its Attorney-in-fact WELLS FARGO BANK, )
N.A., WELLS FARGO BANK, N.A., and
)
WELLS FARGO ASSET SECURITIES
)
CORPORATION,
)
)
Defendants.
)
)

Case No.: 2:17-cv-01514-JCM-NJK
STIPULATION AND ORDER
ALLOWING PLAINTIFF’S
DEPOSITION TO TAKE PLACE
AFTER DISCOVERY DEADLINE
AND EXTENDING DEADLINE
FOR DISPOSITIVE MOTIONS
AND JOINT PRE-TRIAL ORDER
(First Request)

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Plaintiff Edyta Gryglak and Defendants HSBC Bank USA, N.A., as trustee for Wells
Fargo Home Equity Asset-Backed Certificates, Series 2006-3, by its Attorney-in-fact Wells
Fargo Bank, N.A., Wells Fargo Bank, N.A. and Wells Fargo Asset Securities Corporation
(collectively, “Wells Fargo” and with the plaintiff, the “Parties”)) agree as set forth below to
take Plaintiff’s deposition after the close of discovery on August 17, 2018, to extend the deadline
for dispositive motions from August 13, 2018 to September 13, 2018, and to extend the deadline
for pre-trial orders from September 13, 2018 to October 16, 2018. This is the Parties’ first
request for an extension of time of the dispositive motions and joint pre-trial order.
WHEREAS the current discovery deadline is Friday, July 13, 2018;
WHEREAS the current deadlines to file dispositive motions and the joint pre-trial order
are August 13, 2018 and September 13, 2018, respectively;
WHEREAS plaintiff’s deposition has not yet taken place due to plaintiff’s prior

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scheduling issues;
WHEREAS plaintiff’s deposition is currently scheduled to take place on Thursday, July

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12, 2018;
WHEREAS plaintiff’s lead counsel is no longer available due to an unexpected personal

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emergency involving a close friend with terminal brain cancer;
WHEREAS Wells Fargo has generously agreed to reschedule plaintiff’s deposition for a

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subsequent date provided the Court permits the deposition to occur after the July 13, 2018

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discovery cut-off;
WHEREAS August 17, 2018 is the most convenient date for plaintiff’s rescheduled

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deposition considering the schedules of Ms. Gryglak and counsel for the Parties;
Whereas, August 17, 2018, the date of the continued deposition, is after the deadline for

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dispositive motions, therefore the Parties request that the dispositive motion deadline be

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continued for thirty days (30) or until September 13, 2018.1 In conjunction with this, the Parties

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request that the deadline for the pre-trial order be continued for thirty days (30) after that, or until

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October 16, 2018. This is the Parties’ first request for an extension of these deadlines, and is

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requested due to the circumstances detailed above, and the Parties’ schedules. It is made in good

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faith and is not intended to cause delay.

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IT IS HEREBY STIPULATED AS FOLLOWS:

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1.

The deposition of plaintiff Edyta Gryglak is permitted to proceed on August 17,

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The deadlines to file dispositive motions and the joint pre-trial order are continued

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2018.

for thirty days, until Monday, September 13, 2018 and Monday, October 16, 2018, respectively.

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The Parties uploaded a prior stipulation continuing the deposition to August 17, 2018
that did not address the dispositive motion deadline or other deadlines. [ECF No.37] The Court
denied that stipulation without prejudice. [ECF No.38]. The Parties submit this Stipulation to
remedy those defects and address the dispositive motion deadlines.
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Dated this 11th day of July 2018.

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VEGAS WEST ATTORNEYS
Counsel for Plaintiff

SNELL & WILMER L.L.P.
Counsel for Defendants

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/s/ Boris Avramski
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Boris Avramski, Esq.
Nevada Bar No. 11350
VEGAS WEST ATTORNEYS
5594 South Fort Apache Road, Suite 120
Las Vegas, NV 89148
Phone: [phone]
Fax: [phone]
[e-mail]

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IT IS SO ORDERED:

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____________________________________________
UNITED STATES MAGISTRATE JUDGE

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July 12, 2018
DATED: ___________________________

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/s/ Blakeley E. Griffith
__________________________
Blakeley E. Griffith, Esq.
Nevada Bar No. 12386
SNELL & WILMER L.L.P.
3883 Howard Hughes Parkway
Las Vegas, NV 89169
Phone: [phone]
Fax: [phone]
[e-mail]