Lane et al v. Conestoga Settlement Services, LLC et al

Filing 19

ORDER Granting #17 Stipulation for Extension of Time. James Settlement Services, LLC answer due 11/9/2020. Signed by Magistrate Judge Brenda Weksler on 10/14/2020. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:20-cv-01716-APG-BNW Document 19 Filed 10/14/20 Page 1 of 3

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WILLIAM P. VOLK, ESQ.
Nevada Bar No. 6157
Email: [e-mail]
JESSICA M. LUJAN, ESQ.
Nevada Bar No. 14913
Email: [e-mail]
HOLLEY DRIGGS
400 South Fourth Street, Third Floor
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]

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and

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MILTON G. HAMMOND (pro hac vice forthcoming)
Texas Bar No. 08867720
RAMJI LAW GROUP, P.C.
9186 Katy Freeway
Houston, TX 77055
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Service Email: [e-mail]

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Attorneys for Defendant James Settlement Services, LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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KENNETH LANE, et al.,

Case No.: 2:20-cv-01716-APG-BNW

Plaintiffs,

STIPULATION TO EXTEND THE
TIME FOR DEFENDANT JAMES
SETTLEMENT SERVICES, LLC
TO RESPOND TO COMPLAINT

v.
CONESTOGA SETTLEMENT SERVICES,
LLC, et al.,
Defendants.

(FIRST REQUEST)

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Plaintiffs, by and through their counsel of record, Reese Marketos LLP and King &
Durham, PLLC, and Defendant James Settlement Services, LLC (“JSS”), by and through its

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counsel of record, Ramji Law Group, hereby stipulate to an extension of time by which JSS must
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Case 2:20-cv-01716-APG-BNW Document 19 Filed 10/14/20 Page 2 of 3

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respond to the Complaint by, and including, November 9, 2020 (November 8 being a Sunday).
This Stipulation is made and based upon the following:

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1.

Defendants engaged in tortious conduct and misrepresented certain aspects of life settlement
investments. (ECF No. 1). Plaintiffs seek certification to represent a class of similarly situated
individuals across the country. Id.
2.

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3.

Counsel for JSS represent that they have recently been engaged and require

additional time to evaluate Plaintiffs’ allegations and prepare a response, taking into account the
exercise of due diligence.
4.

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JSS was served with the Complaint on September 18, 2020. JSS’s response is

currently due October 9, 2020.

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Plaintiffs filed their Complaint on September 17, 2020, in which they allege that

In light of the foregoing, the parties agree and request that JSS shall have up to, and

including, November 9, 2020, to respond to the Complaint.
5.

JSS thus requests that the Court accept this Stipulation and enter this proposed

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order. This is the first request for an extension of time. This Stipulation is entered into in good
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faith and not for purposes of delay.

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Case 2:20-cv-01716-APG-BNW Document 19 Filed 10/14/20 Page 3 of 3

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6.

Counsel for JSS will submit a pro hac vice motion on or before the requested

answer date.

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DATED this 8th day of October, 2020.

DATED this 8th day of October, 2020.

By: /s/ William P. Volk

By: /s/ Matthew L. Durham (with permission)

WILLIAM P. VOLK, ESQ.
Nevada Bar No. 6157
JESSICA M. LUJAN, ESQ.
Nevada Bar No. 14913
HOLLEY DRIGGS
400 South Fourth Street, Third Floor
Las Vegas, Nevada 89101

MATTHEW L. DURHAM, ESQ.
Nevada Bar No. 10342
KING DURHAM
6385 S. Rainbow Rd., Ste. 220
Las Vegas, Nevada 89118

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Counsel for Plaintiff Kenneth Lane

And
MILTON G. HAMMOND, ESQ.
(pro hac vice forthcoming)
Texas Bar No. 08867720
RAMJI LAW GROUP, LLC
9186 Katy Freeway
Houston, TX 77055

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Counsel for Defendant JSS
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IT IS SO ORDERED
ORDER

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DATED: 12:23 pm, October 14, 2020
IT IS SO ORDERED.

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BRENDA WEKSLER
__________________________________________
UNITED STATES MAGISTRATE JUDGE
UNITED STATES DISTRICT JUDGE
DATED this _____ day of ____________________, 2020.

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