Sipple v. Zions Bancorporation, N.A.

Filing 12

ORDER Granting #11 Stipulation for Extension of Time re #1 Complaint within Petition for Removal. Zions Bancorporation, N.A. answer due 7/7/2021. Signed by Magistrate Judge Nancy J. Koppe on 6/7/2021. (Copies have been distributed pursuant to the NEF - DRS) Modified Judge's name on 6/7/2021 (SLD).

Case 2:21-cv-00904-GMN-NJK Document 11 Filed 06/04/21 Page 1 of 3

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JACOB D. BUNDICK, ESQ.
Nevada Bar No. 9772
MICHAEL R. HOGUE, ESQ.
Nevada Bar No. 12400
GREENBERG TRAURIG, LLP
10845 Griffith Peak Drive, Ste. 600
Las Vegas, NV 89135
Tel: [phone]
Fax: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Defendant
Zions Bancorporation, N.A.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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LINDA LEE SIPPLE, ON BEHALF OF
HERSELF AND ALL OTHERS SIMILARLY
SITUATED

Case No. 2:21-cv-00904-GMN-NJK

v.

STIPULATION AND ORDER TO
EXTEND THE TIME FOR DEFENDANT
ZIONS BANCORPORATION, N.A. TO
RESPOND TO THE COMPLAINT

ZIONS BANCORPORATION, N.A.,

[SECOND REQUEST]

Plaintiff,

Defendant.

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Plaintiff Linda Lee Sipple (“Sipple”) and defendant Zions Bancorporation, N.A. (“Zions”), by
and through their undersigned attorneys, hereby stipulate and agree as follows:

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1.

Plaintiff filed a putative class action Complaint against Zions in the Eighth Judicial

District Court for the State of Nevada in the above-captioned action on February 17, 2021.

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2.

Plaintiff served the Complaint on Zions on April 8, 2021.

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3.

On May 7, 2021, Zions removed the matter to this Court pursuant to 28 U.S.C. § 1441

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and 28 U.S.C. § 1332(d).

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4.

Pursuant to Fed. R. Civ. P. 81(c)(2), the deadline for Zions to respond to the Complaint

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was May 14, 2021.

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Case 2:21-cv-00904-GMN-NJK Document 11 Filed 06/04/21 Page 2 of 3

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5.

On May 17, 2021, the Court granted the parties’ Stipulation and Order to Extend the

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Time for Defendant to Respond to the Complaint [First Request], thereby extending the response date

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to June 7, 2021.

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6.

On May 28, 2021, Sipple advised that she may seek to remand this matter. On June 2,

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2021, the parties met and conferred, but did not resolve the dispute, and Sipple intends to file her

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remand motion no later than June 7, 2021.

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Based on this stated intention, the parties submitted a Stipulation and Order to Extend

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the Time for Defendant to Respond to the Complaint [Second Request] [Doc. 8] on June 3, 2021,

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requesting the Court extend the response deadline until twenty-one (21) days after the Court enters an

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order on the remand motion.
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The Court denied the stipulation [Doc. 9], noting (a) that it was uncertain if Sipple would

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seek remand and (b) that the parties did not explain how the stipulation would conserve judicial

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resources by effectively staying discovery for an unknown period of time.

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9.

Regarding the Court’s initial concern, on June 4, 2021, Sipple confirmed she would be

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filing her motion for remand by midnight the same day. As such, Sipple has stated that she will file a

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motion for remand and the uncertainty identified by the Court has been removed.

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10.

As to the Court’s second concern, the point is well taken. The parties contend that

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proceeding immediately with discovery in this case will force the expenditure of unnecessary party

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resources that can better be devoted to other potential avenues for the resolution of this matter,

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including preliminary settlement discussions that will continue and likely be influenced by the

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substance of the remand motion as well as the Court’s order regarding said motion.

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11.

That being said, the parties respect the Court’s view of an unlimited extension. As such,

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the parties have further conferred and agreed to extend the deadline for Zions to respond to the

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Complaint by thirty (30) days from June 7, 2021 up to and including July 7, 2021.

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12.

Good cause supports the request because the parties will have an opportunity to evaluate

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the merits of Sipple’s remand motion, explore any impact on the potential for further settlement

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discussions, and prepare an appropriate response to the pending Complaint.

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Case 2:21-cv-00904-GMN-NJK Document 11 Filed 06/04/21 Page 3 of 3

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13.

The parties have previously requested one extension of the deadline to respond to the

Complaint by this Court. No other requests have been made regarding any other deadlines.

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14.

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THEREFORE, and for good cause shown, the parties respectfully request that the deadline for

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The parties enter into this stipulation in good faith and not for the purpose of delay.

Zions to file a response to the Complaint be extended up to and including July 7, 2021.
IT IS SO STIPULATED.

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DATED this 4th day of June, 2021.

DATED this 4th day of June, 2021.

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GREENBERG TRAURIG, LLP

LAW OFFICES OF BURAK S. AHMED, PC

/s/ Jacob D. Bundick
JACOB D. BUNDICK, ESQ.
Nevada Bar No. 9772
MICHAEL R. HOGUE, ESQ.
Nevada Bar No. 12400
10845 Griffith Peak Drive, Ste. 600
Las Vegas, Nevada 89135
Attorneys for Defendant
Zions Bancorporation, N.A.

/s/ Burak S. Ahmed
BURAK S. AHMED, ESQ.
Nevada Bar No. 12547
3651 Lindell Road, Suite D812
Las Vegas, Nevada 89103
Attorneys for Plaintiff Linda Lee Sipple

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ORDER
IT IS SO ORDERED:

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______________________________________
HONORABLE NANCY J. KOPPE
UNITED STATES MAGISTRATE JUDGE
June 7, 2021
DATED: ______________________________

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