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)

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Case 2:20-cv-01716-APG-BNW Document 19 Filed 10/14/20 Page 1 of 3 1 6 WILLIAM P. VOLK, ESQ. Nevada Bar No. 6157 Email: wvolk@nevadafirm.com JESSICA M. LUJAN, ESQ. Nevada Bar No. 14913 Email: jlujan@nevadafirm.com HOLLEY DRIGGS 400 South Fourth Street, Third Floor Las Vegas, Nevada 89101 Telephone: (702) 791-0308 Facsimile: (702) 791-1912 7 and 8 MILTON G. HAMMOND (pro hac vice forthcoming) Texas Bar No. 08867720 RAMJI LAW GROUP, P.C. 9186 Katy Freeway Houston, TX 77055 Telephone: (832) 674-0209 Facsimile: (866) 672-3372 Email: mhammond@calltheram.com Service Email: service@ramjilaw.com 2 3 4 5 9 10 11 12 13 Attorneys for Defendant James Settlement Services, LLC 14 UNITED STATES DISTRICT COURT 15 DISTRICT OF NEVADA 16 17 18 19 20 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) 21 22 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 23 counsel of record, Ramji Law Group, hereby stipulate to an extension of time by which JSS must 24 25 1 Case 2:20-cv-01716-APG-BNW Document 19 Filed 10/14/20 Page 2 of 3 1 2 respond to the Complaint by, and including, November 9, 2020 (November 8 being a Sunday). This Stipulation is made and based upon the following: 3 4 5 6 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. 7 10 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. 11 12 JSS was served with the Complaint on September 18, 2020. JSS’s response is currently due October 9, 2020. 8 9 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 13 order. This is the first request for an extension of time. This Stipulation is entered into in good 14 faith and not for purposes of delay. 15 /// 16 /// 17 /// 18 /// 19 /// /// 20 /// 21 /// 22 /// 23 /// 24 /// 25 2 Case 2:20-cv-01716-APG-BNW Document 19 Filed 10/14/20 Page 3 of 3 1 2 6. Counsel for JSS will submit a pro hac vice motion on or before the requested answer date. 3 4 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 5 6 7 8 9 10 11 12 13 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 14 Counsel for Defendant JSS 15 16 17 IT IS SO ORDERED ORDER 18 19 DATED: 12:23 pm, October 14, 2020 IT IS SO ORDERED. 20 21 22 23 BRENDA WEKSLER __________________________________________ UNITED STATES MAGISTRATE JUDGE UNITED STATES DISTRICT JUDGE DATED this _____ day of ____________________, 2020. 24 25 3

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