Lefrancis v. Experian Information Solutions, Inc. et al

Filing 44

ORDER Granting 41 Stipulation for Extension of Time re 37 Amended Complaint (First Request). Specialized Loan Servicing, LLC answer due 4/10/2018. Signed by Chief Judge Gloria M. Navarro on 3/27/2018. (Copies have been distributed pursuant to the NEF - MR)

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Michael W. Stoltzman Jr., Bar No. 14282
[e-mail]
THE RYAN FIRM
A Professional Corporation
140 Deerfield Road
Dayton, NV 89403
Telephone [phone]; Fax [phone]

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Attorneys for Defendant Specialized Loan Servicing LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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A Professional Corporation

THE RYAN FIRM

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KATHY A. LEFRANCIS,

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Plaintiff,
vs.
EXPERIAN INFORMATION
SOLUTIONS, INC., CAPITAL ONE
BANK (USA) N.A., DITECH
FINANCIAL LLC, OCWEN LOAN
SERVICING, LLC, AND
SPECIALIZED LOAN SERVICING,
LLC,
Defendants.

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CASE NO.: 2:17-cv-02780-GMN-CWH
STIPULATION TO EXTEND TIME
FOR DEFENDANT SPECIALIZED
LOAN SERVICING LLC TO RESPOND
TO PLAINTIFF’S [SECOND] FIRST
AMENDED COMPLAINT
[FIRST STIPULATED EXTENSION AS
TO PLAINTIFF’S [SECOND] FIRST
AMENDED COMPLAINT]
Trial Date:

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Stipulation

None set.

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PLEASE TAKE NOTICE that, pursuant to Local Rules IA 6-1 and 6-2,

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Defendant Specialized Loan Servicing LLC (“SLS” or “Defendant”) and Plaintiff Kathy

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A. Lefrancis (“Plaintiff”) hereby stipulate to extend the deadline for Defendant to

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respond to Plaintiff’s [Second] First Amended Complaint (“FAC”) from March 27, 2018,

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to April 10, 2018. The parties agree to this extension in good faith to allow Defendant

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additional time to review and investigate Plaintiff’s allegations prior to responding to the

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FAC and to allow the parties a further opportunity to explore possible settlement options

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prior to incurring significant litigation expenses. This is the first stipulated extension of

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Defendant’s deadline to respond to the FAC.

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A Professional Corporation

THE RYAN FIRM

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DATED: March 27, 2018

THE RYAN FIRM
A Professional Corporation

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By: /s/ Michael W. Stoltzman, Jr.
MICHAEL W. STOLTZMAN JR.
Attorneys for Defendant Specialized
Loan Servicing LLC

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DATED: March 27, 2018

KNEPPER & CLARK LLC

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By: /s/ Matthew I. Knepper
MATTHEW I. KNEPPER
Attorneys for Plaintiff Kathy A.
Lefrancis

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IT IS SO ORDERED.
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DATED this ____ day of March, 2018.

DATED: ____________

_____________________________________
_____________________________

Gloria M. Navarro, Chief COURT JUDGE
UNITED STATES DISTRICTJudge
United States District Court
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Stipulation

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PROOF OF SERVICE
I am over the age of eighteen years and not a party to the within action. I am
employed by The Ryan Firm, A Professional Corporation, whose business address is: 30
Corporate Park, Suite 310, Irvine, CA 92606.

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THE RYAN FIRM

A Professional Corporation

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On March 27, 2018, I served the within document(s) described as:
STIPULATION TO EXTEND TIME FOR DEFENDANT SPECIALIZED LOAN
SERVICING LLC TO RESPOND TO PLAINTIFF’S [SECOND] FIRST
AMENDED COMPLAINT [FIRST STIPULATED EXTENSION AS TO
PLAINTIFF’S [SECOND] FIRST AMENDED COMPLAINT] on the interested
parties in this action:
by transmitting via electronic mail the document(s) listed above to the email
addresses provided by counsel.
by placing the original
addressed as follows:
Name & Address
Haines & Krieger, LLC
David Krieger
8985 S. Eastern Ave.,
Suite 350
Henderson, NV 89123
Knepper & Clark LLC
Matthew Knepper
10040 W. Cheyenne
Ave., Suite 170-109
Las Vegas, NV 89129
Naylor & Braster
Andrew Sharples
1050 Indigo Drive,
Suite 200
Las Vegas, NV 89145
Brownstein Hyatt
Farber Schreck, LLP
Arthur Zorio
5371 Kietzke Lane
Reno, NV 89511
Bryan Cave
Sean McElenney
Two North Central Ave.,
#2200
Phoenix, AZ 85004

true copy(ies) thereof enclosed in sealed envelope(s)
addressed as stated on the attached mailing list.

Telephone / Fax / E-mail
Tel: [phone]
Fax: [phone]
Email:
[e-mail]

Role
Attorney for Plaintiff
Kathy A. Lefrancis

Tel: [phone]
Attorney for Plaintiff
Fax: [phone]
Kathy A. Lefrancis
Email:
[e-mail]
Tel: [phone]
Fax: [phone]
Email: [e-mail]

Attorney for
Defendant Experian
Information
Solutions, Inc.

Tel: [phone]
Fax: [phone]
Email: [e-mail]

Attorney for
Defendant Ocwen
Loan Servicing, LLC

Tel: [phone]
Fax: [phone]
Email:
[e-mail]

Attorney for
Defendant Ocwen
Loan Servicing, LLC

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Proof of Service

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CM/ECF (U.S. District Court, District of Nevada, Local Civil Rule LR IC 4-1.)—
The NEF that is automatically generated by the Court’s Electronic Filing System
constitutes service of the filed document(s) on registered users. All parties who
are not registered, if any, were served in the manner set forth above.
(Federal) I declare that I am employed in the office of a member of the bar of this
Court at whose direction the service was made.
Executed on March 27, 2018, at Irvine, California.

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/s/ Alena Ivanov
ALENA IVANOV

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THE RYAN FIRM

A Professional Corporation

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Proof of Service