Mott v. Trinity Financial Services, LLC et al

Filing 33

ORDER Granting 32 First Stipulation for Extension of Time Re: 27 Motion for Sanctions and 28 Motion for Partial Summary Judgment. Defendants' Responses to 27 due by 9/7/2018. Defendants' Responses to 28 due by 9/14/2018. Signed by Judge Richard F. Boulware, II on 8/20/2018. (Copies have been distributed pursuant to the NEF - SLD)

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Richard J. Reynolds (SBN 11864)
E-mail: [e-mail]
Allan E. Ceran (admitted pro hac vice)
E-mail: [e-mail]
BURKE, WILLIAMS & SORENSEN, LLP
1851 East First Street, Suite 1550
Santa Ana, CA 92705-4067
Tel: [phone] Fax: [phone]

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Michael R. Brooks, Esq.
Nevada Bar No. 7287
E-mail: [e-mail]
KOLESAR & LEATHAM
400 S. Rampart Blvd., Suite 400
Las Vegas, NV 89145
Tel: [phone] Fax: [phone]

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Attorneys for Defendants
TRINITY FINANCIAL SERVICES, LLC and
TRINITY RECOVERY SERVICES, LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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RODNEY MOTT,
Plaintiff,

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Case No. 2:17-cv-01754-RFB-GWF

v.
TRINITY FINANCIAL SERVICES, LLC,
AND TRINITY RECOVERY SERVICES,
LLC,

STIPULATION FOR EXTENSION OF
TIME TO RESPOND TO PLAINTIFF’S
MOTION FOR TERMINATING
SANCTIONS AND MOTION FOR
PARTIAL SUMMARY JUDGMENT;
ORDER [PROPOSED] THEREON
(FIRST REQUEST)

Defendants.

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On August 10, 2018, plaintiff Rodney Mott (“Plaintiff”) filed a motion for terminating
sanctions and a motion for partial summary judgment. Currently, defendants Trinity Financial
Services, LLC and Trinity Recovery Services, LLC (collectively, “Defendants”) must respond to
Plaintiff’s motion for terminating sanctions on or before August 24, 2018 and to Plaintiff’s
motion for partial summary judgment on or before August 31, 2018.
Pursuant to LR 6-1 and LR 7-2, Plaintiff and Defendants, by and through their respective

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B URKE , W ILLIAMS &
S ORENSEN , LLP
ATTORNEYS AT LAW
SANTA ANA

LA #4820-8068-6192 v1

-1-

STIPULATION FOR EXTENSION OF TIME
TO RESPOND

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counsel of record, hereby stipulate and request that this Court (1) extend to and including

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September 7, 2018 the time by which Defendants must respond to Plaintiff’s motion for

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terminating sanctions and (2) extend to and including September 14, 2018 the time by which

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Defendants must respond to Plaintiff’s motion for partial summary judgment.

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There is good cause for the requested extension. The parties are discussing a potential

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settlement of this matter and believe that it would be in the interest of justice and more efficient to

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devote their time during the upcoming weeks on efforts to settle this matter rather than expending

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time and money preparing responses and replies to the pending motions.

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IT IS SO STIPULATED.
Dated August 17, 2018
/s/ Miles N. Clark
Matthew I. Knepper, Esq.
Nevada Bar No. 12796
Miles N. Clark, Esq.
Nevada Bar No. 13848
KNEPPER & CLARK LLC
Email: [e-mail]
Email: [e-mail]
David H. Krieger, Esq.
Nevada Bar No. 9086
HAINES & KRIEGER, LLC
Email: [e-mail]
Counsel for Plaintiff

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ORDER
IT IS SO ORDERED.
August 20
Dated: ____ _____, 2018

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/s/ Michael R. Brooks
Michael R. Brooks, Esq.
Nevada Bar No. 7287
KOLESAR & LEATHAM
400 S. Rampart Boulevard, Suite 400
Las Vegas, NV 89145
Email: [e-mail]
Richard J. Reynolds, Esq.
BURKE, WILLIAMS & SORENSEN, LLP
1851 East First Street, Suite 1550
Santa Ana, CA 92705, CA 92705
Email: [e-mail]
Counsel for Defendants
Trinity Financial Services, LLC and Trinity
Recovery Services, LLC

__________________________
RICHARD F. BOULWARE, II
UNITED STATES DISTRICT JUDGE
United States District Court

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B URKE , W ILLIAMS &
S ORENSEN , LLP
ATTORNEYS AT LAW
SANTA ANA

LA #4820-8068-6192 v1

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STIPULATION FOR EXTENSION OF TIME
TO RESPOND