Federal Trade Commission v. Consumer Defense LLC et al

Filing 291

ORDER Granting 290 Stipulation for Extension of Time re 255 Motion for Summary Judgment (Second Request). Signed by Judge James C. Mahan on 9/27/2019. (Copies have been distributed pursuant to the NEF - MR)

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Jonathan Hanley
3241 East Granite Point Circle
Sandy Utah 84092
801-913-5504 |
[e-mail]

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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA

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FEDERAL TRADE COMMISSION,

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Plaintiff,

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v.

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CASE NO. 2:18-CV-00030-JCM-BNW
STIPULATION TO EXTEND DEADLINE
FOR DISPOSITIVE MOTIONS

CONSUMER DEFENSE, LLC, et. al.,

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Defendants.

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COME NOW, Jonathan Hanley in his capacity as a pro se Defendant and Defendants,

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CONSUMER DEFENSE, LLC; CONSUMER LINK, INC. AMERICAN HOME LOAN
COUNSELORS; AMERICAN HOME LOANS, LLC; CONSUMER DEFENSE GROUP, LLC
F/K/A MODIFICATION REVIEW BOARD, LLC; BROWN LEGAL, INC.; FMG PARTNERS,

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LLC; ZINLEY, LLC; SANDRA X. HANLEY, by and through their attorney of record, and the

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Plaintiff, FEDERAL TRADE COMMISSION, by and through its attorneys of record, and hereby

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stipulate, agree and seek this Court’s Order as follows:

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1.

On January 8, 2018, the FTC filed a complaint for permanent injunction and other

equitable relief against individuals Jonathan Hanley, Benjamin Horton, and Sandra Hanley, and

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against the entities Consumer Defense, LLC (Nevada), Consumer Link, Inc. (the “Nevada

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Corporate Defendants”), Preferred Law, PLLC, American Home Loan Counselors, Consumer

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Defense Group, LLC, Consumer Defense, LLC (Utah), Brown Legal, Inc., AM Property

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STIPULATION TO EXTEND DEADLINE FOR DISPOSITIVE MOTIONS - 1

Case 2:18-cv-00030-JCM-BNW Document 290 Filed 09/27/19 Page 2 of 3

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Management, LLC, FMG Partners, LLC, and Zinly, LLC (the “Utah Corporation Defendants”)

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(all collectively the “Corporate Defendants”) . (ECF No. 1.)

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2.

The current Scheduling Order in this case calls for the filing of all dispositive motions on

or before July 15, 2019. (ECF 171.)

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3.

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of the Defendants, including the Corporate Defendants. (ECF No. 233.)

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4.

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On June 5, 2019, D. Brian Boggess entered his Notice of Appearance as Counsel for all

The deposition of the FTC’s expert witness, William Violette, was held on September 5th

2019.
5.

Due to the complex nature of this case the substantial involvement of Jonathan Hanley

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has been necessary. As a result of financial difficulty, The Hanley family has been forced to

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move 2 times in the last 60 days and is still in the process of their 2nd move thereby allowing

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Jonathan Hanley little time to be involved in the response to plaintiff’s Motion for Summary

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Judgement.
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As a result of extreme financial difficulty of the Hanleys, the corporate defendants will

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join in the response that is filed by Jonathan Hanley.

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7.

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which caused a half day on Thursday September 26th 2019 and their children do not have school

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The school that the Hanley’s children go to had parent teacher conferences this week

Friday September 27th 2019.
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It is also their son’s birthday today. Previous plans had been made causing some familial

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commitments.

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9.

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additional 1 day shall apply to the oppositions of all defendants. Accordingly, the response will

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The parties conferred on September 27th 2019 and reached an agreement that an

need to be filed on or before September 30th 2019.
STIPULATION TO EXTEND DEADLINE FOR DISPOSITIVE MOTIONS - 2

Case 2:18-cv-00030-JCM-BNW Document 290 Filed 09/27/19 Page 3 of 3

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10.

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to the plaintiff’s motion for Summary Judgment and allow the remaining defendants to join in

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The parties believe it reasonable to allow Jonathan Hanley an additional 1 day to respond

that response.
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Replies, if any, would be due pursuant to the applicable Federal Rules of Civil Procedure

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and the Local Rules of this Court.

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12.

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purposes of delay.

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13.

This stipulation is made in good faith among and at the request of the parties, and not for

The parties deem it reasonable that this need be the last extension of time for the purposes

of responding to the Plaintiff’s motion for summary judgement.

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BOGGESS LAW GROUP

ALDEN F. ABBOTT
General Counsel

/s/D. Brian Boggess
D Brian Boggess
Nevada Bar No. 4537
7495 West Azure Drive, Suite 211
Telephone: [phone]
Fax: [phone]
Email: [e-mail]
Attorney for Defendants

/s/Gregory A. Ashe (with permission)
GREGORY A. ASHE
JASON SCHALL
Federal Trade Commission
600 Pennsylvania Avenue NW
Washington, DC 20580
Telephone: [phone] (Ashe)
Telephone: [phone] (Schall)
Facsimile: 202-326-3768
Email: [e-mail], [e-mail]

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Dated: September 27th 2019

/s/ Jonathan Hanley
Jonathan P. Hanley

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Respectfully Submitted,

IT IS SO ORDERED:

______________________________
Honorable James C. Mahan
United States District Judge
September 27, 2019
DATED:_______________________

STIPULATION TO EXTEND DEADLINE FOR DISPOSITIVE MOTIONS - 3