Thornton v. Portola Del Sol Operator, LLC et al

Filing 25

ORDER Granting 24 Stipulation for Extension of Time (Second Request) re 1 Complaint. Apartment Management Consultants, LLC answer due 3/10/2023. Signed by Magistrate Judge Brenda Weksler on 2/22/2023. (Copies have been distributed pursuant to the NEF - YAW)

Case 2:21-cv-01123-APG-BNW Document 25
24 Filed 02/22/23
02/21/23 Page 1 of 4

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Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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Amy F. Sorenson, Esq.
Nevada Bar No. 12495
SNELL & WILMER L.L.P.
15 West South Temple, Suite 1200
Salt Lake City, UT 84101
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Kelly H. Dove, Esq.
Nevada Bar No. 10569
SNELL & WILMER L.L.P.
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, NV 89169
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Defendant
Apartment Management Consultants, LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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UNITED STATES OF AMERICA ex rel.
PEGGY THORNTON, Realtor,

Case No. 2:21-cv-01123-APG-BNW

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and

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PEGGY THORNTON,

STIPULATION AND ORDER TO
EXTEND DEADLINE TO FILE
RESPONSE TO COMPLAINT

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Plaintiff,

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vs.

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PORTOLA DEL SOL OPERATOR, LLC, a
foreign limited-liability company; TMIF II
PORTOLA, LLC, a foreign limited-liability
company; APARTMENT MANAGEMENT
CONSULTANTS, LLC, a foreign limited
liability company; and RENE
RICHARDSON, as AGENT of PORTOLA
DEL SOL OPERATOR, LLC,

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Defendants.

(Second Request)

Case 2:21-cv-01123-APG-BNW Document 25
24 Filed 02/22/23
02/21/23 Page 2 of 4

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Plaintiff Peggy Thornton (“Plaintiff”) and Defendant Apartment Management Consultants,

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LLC (“Defendant” or “AMC”) (collectively, the “Parties”), by and through their undersigned

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counsel, for good cause shown, hereby stipulate and agree to extend AMC’s deadline to file its

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response to Plaintiff’s Complaint [ECF No. 1] from February 21, 2023, to March 10, 2023 for the

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following reasons:

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1.

Plaintiff filed the Complaint on June 14, 2021 [ECF No. 1].

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2.

The Complaint was unsealed on December 9, 2022 upon the United States’

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AMC’s response to the Complaint was originally due on January 18, 2023.

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4.

The Parties had informally agreed to extend the deadline to respond to February 1,

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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Snell & Wilmer

declining intervention [ECF No. 18].

2023 prior to AMC’s retaining counsel.

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about January 26, 2023.

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6.

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The Parties now agree to allow AMC an additional extension of time to respond to

the Complaint, which request is supported by good cause.

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The Parties previously stipulated to extend the deadline for AMC to respond to the

Complaint to and including February 21, 2023.

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Undersigned counsel, Snell & Wilmer L.L.P. was retained to represent AMC on or

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While AMC and its counsel have worked diligently to evaluate the allegations in the

Complaint, they require modest additional time.

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9.

As AMC is not presently the property manager, it is taking additional time to locate

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relevant documentation. At the same time, undersigned counsel and their core litigation team has

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faced some personal obstacles that have impeded their ability to work, including the post-partum

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hospitalization of a spouse and a school-age child currently suffering from COVID.

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10.

No other defendant has yet appeared. This extension request is sought in good faith

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and is not made for the purpose of delay.

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///

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///

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Case 2:21-cv-01123-APG-BNW Document 25
24 Filed 02/22/23
02/21/23 Page 3 of 4

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THEREFORE, the Parties respectfully request an extension for AMC to file its response to
the Complaint until March 10, 2023.

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Dated: February 21, 2023

Dated: February 21, 2023

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NEVADA LEGAL SERVICES, INC.

SNELL & WILMER L.L.P.

By: /s/Elizabeth S. Carmona
Elizabeth S. Carmona, Esq.
Kristopher S. Pre, Esq.
530 S. 6th St.
Las Vegas, NV 89101

By: /s/ Kelly H. Dove
Amy F. Sorenson, Esq.
Nevada Bar No. 12495
SNELL & WILMER L.L.P.
15 West South Temple, Suite 1200
Salt Lake City, UT 84101

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Attorneys for Plaintiff Peggy Thornton

Kelly H. Dove, Esq.
Nevada Bar No. 10569
SNELL & WILMER L.L.P.
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, NV 89169

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Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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Attorneys for Defendant Apartment
Management Consultants, LLC

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ORDER

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IT IS SO ORDERED.

IT IS SO ORDERED

DATED:
DATED: this ____ day of February,
2023.5:45 pm, February 22, 2023

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UNITED STATES DISTRICT COURT OR
BRENDA
WEKSLER
MAGISTRATE
JUDGE
UNITED STATES MAGISTRATE JUDGE

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Case 2:21-cv-01123-APG-BNW Document 25
24 Filed 02/22/23
02/21/23 Page 4 of 4

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CERTIFICATE OF SERVICE

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I, the undersigned, declare under penalty of perjury, that I am over the age of eighteen (18)

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years, and I am not a party to, nor interested in, this action. On this date, I caused to be served a

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true and correct copy of the foregoing STIPULATION AND ORDER TO EXTEND

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DEADLINE TO FILE RESPONSE TO COMPLAINT by method indicated below:

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

BY FAX: by transmitting via facsimile the document(s) listed above to the fax
number(s) set forth below on this date before 5:00 p.m. pursuant to EDCR Rule 7.26(a).
A printed transmission record is attached to the file copy of this document(s).

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BY U.S. MAIL: by placing the document(s) listed above in a sealed envelope with
postage thereon fully prepaid, in the United States mail at Las Vegas, Nevada addressed
as set forth below.

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BY OVERNIGHT MAIL: by causing document(s) to be picked up by an overnight
delivery service company for delivery to the addressee(s) on the next business day.

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BY PERSONAL DELIVERY: by causing personal delivery by, a messenger service
with which this firm maintains an account, of the document(s) listed above to the
person(s) at the address(es) set forth below.

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BY ELECTRONIC SUBMISSION: submitted to the above-entitled Court for
electronic filing and service upon the Court’s Service List for the above-referenced case.

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BY EMAIL: by emailing a PDF of the document listed above to the email addresses of
the individual(s) listed below.

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Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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DATED February 21, 2023

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/s/ Maricris Williams
An employee of SNELL & WILMER L.L.P.

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4891-1097-8386

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