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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Zachary P. Takos, Esq., Nevada Bar No. 11293
TAKOS LAW GROUP, LTD.
1980 Festival Plaza Drive, Suite 300
Las Vegas, Nevada 89135
Telephone: [phone]
Facsimile: 702.924.4422
Email: [e-mail]

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Counsel for Jayem Family L.P.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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FEDERAL NATIONAL MORTGAGE
ASSOCIATION,

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Case No. 2:17-cv-01800-JAD-GWF

Plaintiff,

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v.

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JAYEM FAMILY L.P., and SUN CITY
ANTHEM COMMUNITY ASSOCIATION,
INC.,

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Defendants.

STIPULATION AND ORDER TO
EXTEND RESPONSIVE PLEADING
DEADLINE
(First Request)

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Plaintiff Federal National Mortgage Association (“Fannie Mae”), Defendant Jayem Family

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L.P. (“Jayem”), and Defendant Sun City Anthem Community Association (“Sun City Anthem”)

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(collectively hereinafter referred to as the “Parties”), by and through their respective counsel of

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record, hereby stipulate and agree to extend the deadline for Jayem to respond to the Complaint

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(ECF No. 1). This is the Parties’ first request.

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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

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the title dispute to the property at issue in this case, as well as several other properties where Jayem

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(or its affiliates) and Fannie Mae or Freddie Mac are claiming adverse interests.

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3.

One of the goals of the settlement discussions is to save litigation costs in this action

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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

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and lawsuit, and that time will be needed to gather and collect data for each property, the Parties

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anticipate it will take approximately 90 days to determine if a settlement can be accomplished.

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5.

Additionally, on October 23, 2017, the Court stayed this case in light of the NRED

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mediation scheduled for December 5, 2017, and provided that the Parties can lift the stay following

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the mediation.

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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.

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Dated this 27th day of October, 2017.

Dated this 27th day of October, 2017.

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WRIGHT FINLAY & ZAK

TAKOS LAW GROUP, LTD.

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/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

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Dated this 27th day of October, 2017.

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THE CLARKSON LAW GROUP, P.C.

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/s/ Matthew McAlonis
Matthew McAlonis, Esq., NV Bar No. 11203
2300 West Sahara Avenue, Suite 950
Las Vegas, NV 89102

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IT IS SO ORDERED.

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UNITED STATES MAGISTRATE JUDGE

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Dated:

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10/30/2017