HSBC Bank USA, N.A. v. Flamingo 316, LLC et al

Filing 19

ORDER Granting 15 Stipulation for Extension of Time re 1 Complaint (First Request). Daniela Dadon, Tom Dadon, Dadon Condos, LLC, Flamingo 316, LLC, and Meridian Resorts LLC, 220 E Flamingo Unit 316 Series answer due 10/23/2017. Signed by Magistrate Judge Nancy J. Koppe on 10/11/17. (Copies have been distributed pursuant to the NEF - MR)

Case 2:17-cv-02400-JAD-NJK Document 15 Filed 10/10/17 Page 1 of 3

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LUIS A. AYON, ESQ.
Nevada Bar No. 9752
AYON LAW, PLLC
9205 West Russell Road
Building 3, Suite 240
Las Vegas, Nevada 89148
Telephone:
[phone]
Facsimile:
[phone]
E-Mail:
[e-mail]
Attorneys for Defendants,
Flamingo 316, LLC, Dadon Condos, LLC, Tom Dadon, as Trustee
of T&D Nevada Trust, Daniela Dadon, as Trustee of T&D Nevada Trust,
Meridian Resorts LLC and 220 East Flamingo Unit 316 Series
UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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HSBC BANK USA, N.A. AS TRUSTEE Case No.: 2:17-cv-02400-JAD-NJK
FOR PHH 2007-3,
STIPULATION TO EXTEND TIME TO
Plaintiff,
RESPOND TO PLAINTIFF HSBC BANK
vs.
USA, N.A.’S COMPLAINT
FLAMINGO 316, LLC, a series of Nevada (First Request)
Rental Holdings, LLC; MERIDIAN
PRIVATE RESIDENCES HOMEOWNERS
ASSOCIATION, a Nevada non-profit
corporation; DADON CONDOS, LLC;
TOM DADON and DANIELA DADON,
Trustees of the T&D BEVADA TRUST;
MERIDIAN RESORTS LLC, 220 E.
FLAMINGO
UNIT
316
SERIES;
RICHARD COHEN and individual; IRIS
COHEN, an individual,
Defendants.

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IT IS HEREBY STIPULATED by and between Plaintiff HSBC BANK USA, N.A. AS

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TRUSTEE FOR PHH 2007-3 (hereinafter “HSBC”) and Defendants, FLAMINGO 316, LLC,

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DADON CONDOS, LLC, TOM DADON, AS TRUSTEE OF T&D NEVADA TRUST, DANIELA

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DADON, AS TRUSTEE OF T&D NEVADA TRUST, MERIDIAN RESORTS LLC AND 220

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EAST FLAMINGO UNIT 316 SERIES (hereinafter Flamingo 316, LLC, Dadon Condos, LLC, Tom

AYON LAW, PLLC
9205 W. Russell Road,
Building 3, Suite 240
LAS VEGAS, NEVADA 89148
PHONE: [phone]

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Case 2:17-cv-02400-JAD-NJK Document 15 Filed 10/10/17 Page 2 of 3

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Dadon, as Trustee of T&D Nevada Trust, Daniela Dadon, as Trustee of T&D Nevada Trust, Meridian
Resorts LLC and 220 East Flamingo Unit 316 Series shall be referred to collectively as the “Parties”)
through their respective counsel of record as follows:
WHEREAS, HSBC filed its Complaint on September 13, 2017.
WHEREAS, Parties retained Luis A. Ayon, Esq. of Ayon Law, PLLC as counsel of record on
October 5, 2017.
WHEREAS, counsel for HSBC was notified of the Parties representation via email on October
5, 2017 and counsel for HSBC informed Luis A. Ayon, Esq. that the Parties were individually served
with the Complaint on September 18th & 19th, respectively.
WHEREAS, the Parties’ responsive pleading is due to HSBC’s Complaint on Monday,
October 9, 2017 and HSBC and the Parties are discussing potential settlement of this matter.
Therefore, the additional time will allow counsel to have further discussions toward that resolution.
WHEREAS, The Parties stipulate as follows:
IT IS HEREBY AGREED AND STIPULATED between HSBC and the Parties, by and
through their undersigned attorneys, that the Parties shall have up to and including October 23, 2017
to file its responsive pleading to Plaintiff’s Complaint.
This is the Parties first request for an extension of time to file their responsive pleading to
Plaintiff’s Complaint and is not intended to cause any delay or prejudice to any Party.
Approved as to Form and Content:

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DATED this 10th day of October, 2017.

DATED this 10th day of October, 2017.

AYON LAW, PLLC

BALLARD SPAHR LLP

_/s/ Luis A. Ayon________
LUIS A. AYON, ESQ.
Nevada Bar No. 9752
9205 W. Russell Road
Building 3, Suite 240
Las Vegas, Nevada 89148

_/s/Holly Ann Priest____________
HOLLY ANN PRIEST, ESQ.
Nevada Bar No. 13226
100 N. City Parkway, Suite 1750
Las Vegas, Nevada 89106

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AYON LAW, PLLC
9205 W. Russell Road,
Building 3, Suite 240
LAS VEGAS, NEVADA 89148
PHONE: [phone]

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Case 2:17-cv-02400-JAD-NJK Document 15 Filed 10/10/17 Page 3 of 3

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ORDER
Pursuant to the above Stipulation of HSBC and the Parties, it is ORDERED that:
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The Parties shall have up to and including October 23, 2017 to file its responsive
pleading to Plaintiff HSBC’s Complaint.

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October 11
DATED this _____ day of __________________, 2017.

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_________________________________________
DISTRICT COURT JUDGE
United States Magistrate Juge

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AYON LAW, PLLC
9205 W. Russell Road,
Building 3, Suite 240
LAS VEGAS, NEVADA 89148
PHONE: [phone]

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