Federal National Mortgage Association v. Jayem family L.P. et al

Filing 18

ORDER Granting 17 Stipulation for Extension of Time re 1 Complaint (First Request). Signed by Magistrate Judge George Foley, Jr on 10/30/17. (Copies have been distributed pursuant to the NEF - MR)

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1 4 Zachary P. Takos, Esq., Nevada Bar No. 11293 TAKOS LAW GROUP, LTD. 1980 Festival Plaza Drive, Suite 300 Las Vegas, Nevada 89135 Telephone: 702.856.4629 Facsimile: 702.924.4422 Email: zach@takoslaw.com 5 Counsel for Jayem Family L.P. 2 3 6 UNITED STATES DISTRICT COURT 7 8 DISTRICT OF NEVADA 9 FEDERAL NATIONAL MORTGAGE ASSOCIATION, 10 Case No. 2:17-cv-01800-JAD-GWF Plaintiff, 11 v. 12 JAYEM FAMILY L.P., and SUN CITY ANTHEM COMMUNITY ASSOCIATION, INC., 13 14 Defendants. STIPULATION AND ORDER TO EXTEND RESPONSIVE PLEADING DEADLINE (First Request) 15 16 17 Plaintiff Federal National Mortgage Association (“Fannie Mae”), Defendant Jayem Family 18 L.P. (“Jayem”), and Defendant Sun City Anthem Community Association (“Sun City Anthem”) 19 (collectively hereinafter referred to as the “Parties”), by and through their respective counsel of 20 record, hereby stipulate and agree to extend the deadline for Jayem to respond to the Complaint 21 (ECF No. 1). This is the Parties’ first request. 22 23 24 1. Jayem has retained counsel in this matter after having been served through the Nevada Secretary of State. 2. Fannie Mae and Jayem are currently in settlement discussions in an effort to resolve 25 the title dispute to the property at issue in this case, as well as several other properties where Jayem 26 (or its affiliates) and Fannie Mae or Freddie Mac are claiming adverse interests. 27 3. One of the goals of the settlement discussions is to save litigation costs in this action 28 1 1 2 as well as other lawsuits where Jayem and Fannie Mae or Freddie Mac are parties. 4. Given that the settlement discussions involve multiple or more than one property 3 and lawsuit, and that time will be needed to gather and collect data for each property, the Parties 4 anticipate it will take approximately 90 days to determine if a settlement can be accomplished. 5 5. Additionally, on October 23, 2017, the Court stayed this case in light of the NRED 6 mediation scheduled for December 5, 2017, and provided that the Parties can lift the stay following 7 the mediation. 8 9 10 11 6. Accordingly, the Parties agree that good cause exists to extend Jayem’s responsive pleading deadline to fourteen days after the stay is lifted in this case. The Parties hereby respectfully request that the Court enter an order confirming said deadline. IT IS SO STIPULATED AND AGREED. 12 Dated this 27th day of October, 2017. Dated this 27th day of October, 2017. 13 WRIGHT FINLAY & ZAK TAKOS LAW GROUP, LTD. 16 /s/ Christina V. Miller Christina V. Miller, Esq., NV Bar No. 12448 7785 W. Sahara Avenue, Suite 200 Las Vegas, NV 89117 /s/ Zachary P. Takos Zachary P. Takos, Esq., NV Bar No. 11293 1980 Festival Plaza Drive, Suite 300 Las Vegas, NV 89135 17 Dated this 27th day of October, 2017. 18 THE CLARKSON LAW GROUP, P.C. 14 15 19 20 21 /s/ Matthew McAlonis Matthew McAlonis, Esq., NV Bar No. 11203 2300 West Sahara Avenue, Suite 950 Las Vegas, NV 89102 22 IT IS SO ORDERED. 23 24 UNITED STATES MAGISTRATE JUDGE 25 Dated: 26 27 28 2 10/30/2017

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