Prof-2013-S3 Legal Title Trust, By U.S. Bank National Association v. Flying Frog Avenue Trust

Filing 23

ORDER Granting 22 Stipulation to Extend Time Re: 19 , 21 Motions to Dismiss. Responses due by 12/22/2017. Signed by Judge James C. Mahan on 12/1/2017. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-01933-JCM-GWF Document 22 Filed 11/30/17 Page 1 of 3

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WRIGHT, FINLAY & ZAK, LLP
Edgar C. Smith, Esq.
Nevada Bar No. 05506
Rock K. Jung, Esq.
Nevada Bar No. 10906
7785 W. Sahara Ave., Suite 200
Las Vegas, NV 89117
[phone]; Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff,
PROF-2013-S3 Legal Title Trust,
by U.S. Bank National Association,
as Legal Title Trustee
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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PROF-2013-S3 LEGAL TITLE TRUST, BY
U.S. BANK NATIONAL ASSOCIATION, AS
LEGAL TITLE TRUSTEE

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Plaintiff,

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vs.
FLYING FROG AVENUE TRUST, a Nevada
Limited Liability Company, VENEZIA
COMMUNITY ASSOCIATION, RED ROCK
FINANCIAL SERVICES, LLC, DOE
Individual I-X inclusive; and ROE Business
Entities XI-XX inclusive;

Case No.: 2:17-cv-01933-JCM-GWF

STIPULATION AND ORDER TO
EXTEND DEADLINE TO RESPOND TO
DEFENDANT RED ROCK FINANCIAL
SERVICES, LLC’S MOTION TO
DISMISS [ECF NO. 19] and
DEFENDANT FLYING FROG AVENUE
TRUST’S MOTION TO DISMISS [ECF
NO. 21]

Defendants.

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COMES NOW, Plaintiff, PROF-2013-S3 Legal Title Trust, by U.S. Bank National
Association, as Legal Title Trustee (hereinafter “Plaintiff” or “U.S. Bank”), by and through its
attorney, ROCK K. JUNG, ESQ., of the law firm of Wright, Finlay & Zak, LLP, and Defendant,
Flying Frog Avenue Trust (hereinafter “Flying Frog” or “Defendant”), by and through its
counsel of record, Michael F. Bohn, Esq. and Adam R. Trippiedi, Esq. of the Law Offices of
Michael F. Bohn, Esq., Ltd., and Defendant Red Rock Financial Services, LLC (hereinafter

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Case 2:17-cv-01933-JCM-GWF Document 22 Filed 11/30/17 Page 2 of 3

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“RRFS”), by and through its counsel of record, Steve Scow, Esq. of Koch & Scow, LLC, and

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hereby stipulate and agree as follows:

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WHEREAS on November 7, 2017, Plaintiff filed its First Amended Complaint against

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Defendants seeking quiet title and declaratory relief concerning the real property located at 8970

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Flying Frog Avenue, Las Vegas, Nevada 89148, purportedly sold at a non-judicial foreclosure

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sale on February 4, 2013, to Defendant in satisfaction the HOA’s lien for unpaid assessments.

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WHEREAS on November 17, 2017, RRFS filed a Motion to Dismiss [ECF No. 19].

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WHEREAS the deadline for Plaintiff to file a response to RRFS’s Motion to Dismiss is

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currently set for December 1, 2017.

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WHEREAS on November 22, 2017, FLYING FROG filed a Motion to Dismiss [ECF No.
21].
WHEREAS the deadline for Plaintiff to file a response to FLYING FROG’s Motion to
Dismiss is currently set for December 6, 2017.

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WHEREFORE, based on the foregoing, IT IS HEREBY STIPULATED AND AGREED

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that the deadline for Plaintiff to file a response to RRFS’s Motion to Dismiss should be extended

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to December 22, 2017.

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IT IS FURTHER STIPULATED AND AGREED that the deadline for Plaintiff to file a
response to FROG’s Motion to Dismiss should be extended to December 22, 2017.
DATED this 30th day of November, 2017.
WRIGHT, FINLAY & ZAK, LLP

LAW OFFICES OF MICHAEL F. BOHN, ESQ.,
LTD.

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/s/ Rock K. Jung, Esq.
EDGAR C. SMITH, ESQ.
Nevada Bar No. 05506
E-Mail: [e-mail]
ROCK K. JUNG, ESQ.
Nevada Bar No. 10906
E-Mail: [e-mail]
7785 W. Sahara Ave., Suite 200
Las Vegas, Nevada 89117
Attorneys For: PROF-2013-S# Legal
Title Trust, U.S. Bank National Association,
as Legal Title Trustee

/s/ Michael F. Bohn, Esq.
MICHAEL F. BOHN, ESQ.
Nevada Bar No. 1641
E-Mail: [e-mail]
ADAM R. TRIPPIEDI, ESQ..
Nevada Bar No. 12294
E-Mail: [e-mail]
376 East Warm Springs Road, Suite 140
Las Vegas, NV 89119
Attorneys For:
Flying Frog Avenue Trust

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Case 2:17-cv-01933-JCM-GWF Document 22 Filed 11/30/17 Page 3 of 3

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KOCH & SCOW LLC

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/s/ Steve B. Scow, Esq.
Steve B. Scow, Esq.
Nevada Bar No. 9906
E-Mail: [e-mail]
11500 South Eastern Avenue, Suite 210
Henderson, NV 89052
Attorneys for Defendant,
Red Rock Financial Services
ORDER

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IT IS SO ORDERED.

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UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE

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December 1, 2017
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DATED:

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