Thornton v. Portola Del Sol Operator, LLC et al

Filing 90

ORDER granting 87 Stipulation to Extend Deadlines to Respond and Reply to 81 Motion to Dismiss and 85 Motion to Dismiss. Responses due by 3/1/2024. Replies due by 3/29/2024. Signed by Judge Andrew P. Gordon on 2/20/2024. (Copies have been distributed pursuant to the NEF - CT)

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PETER C. WETHERALL, ESQ.
Nevada State Bar No. 4414
ELIZABETH S. CARMONA, ESQ.
Nevada State Bar No. 14687
KRISTOPHER S. PRE, ESQ.
Nevada State Bar No. 14106
NEVADA LEGAL SERVICES, INC.
701 E. Bridger Avenue, Suite 400
Las Vegas, Nevada 89101
Telephone: [phone], ext. 128
[e-mail]
[e-mail]
[e-mail]
Attorneys for Peggy Thornton
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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

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

and
PEGGY THORNTON,

JOINT STIPULATION AND ORDER
TO EXTEND DEADLINE FOR
THORNTON TO FILE OPPOSITION
TO AMC/RICHARDSON’S MOTION
TO DISMISS AMENDED
COMPLAINT AND STIPULATION
AND ORDER TO EXTEND
DEADLINE FOR
AMC/RICHARDSON TO FILE
REPLY TO THORNTON’S
OPPOSITION

Plaintiff,
v.
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.

(First Request)

Defendants.

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Plaintiff Peggy Thornton (“Thornton”) and Defendants Apartment Management
Consultants, LLC (“AMC”) and Rene Richardson (“Richardson”) (collectively, the “Parties”), by
and through their undersigned counsel, for good cause shown, hereby stipulate and agree to extend
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Thornton’s deadline to file an Opposition to AMC/Richardson’s Motion to Dismiss Amended
Complaint from February 16, 2024, to March 1, 2024.

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Further, the Parties, by and through their undersigned counsel, for good cause shown,

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hereby stipulate and agree to extend AMC/Richardson’s deadline to file a Reply to Thornton’s

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Opposition from March 8, 2024, to March 29, 2024. The Parties have stipulated to the above

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deadlines for the following reasons:
1.

Thornton’s deadline to file an Opposition to AMC/Richardson’s Motion to

Dismiss Amended Complaint is currently February 16, 2024.
2.

Due to a family emergency recently experienced by Elizabeth S. Carmona, Esq.,

Thornton is requesting a two-week extension until March 1, 2024.

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3.

Counsel for AMC/Richardson has agreed to the requested extension.

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4.

Counsel for AMC/Richardson has also requested an extension to file its Reply to

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Thornton’s Opposition. Thornton agreed to an extension up to and including March 29, 2024.
5.

AMC/Richardson’s Reply would be due on March 8, 2024.
6.

7.

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of delay.

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8.

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Due to an upcoming Ninth Circuit oral argument and planned travel the following

week, AMC/Richardson is requesting an extension until March 29, 2024.

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If Thornton’s two-week extension is granted until March 1, 2024,

These extension requests are sought in good faith and are not made for the purpose

Therefore, the Parties hereby stipulate that Thornton’s deadline to file an

Opposition to AMC/Richardson’s Motion to Dismiss Amended Complaint be extended from
February 16, 2024, to March 1, 2024.
9.

Additionally, the Parties hereby stipulate that AMC/Richardson’s deadline to file

a Reply to Thornton’s Opposition be extended from March 8, 2024, to March 29, 2024.

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Dated: February 15, 2024

Dated: February 15, 2024

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NEVADA LEGAL SERVICES, INC.

SNELL & WILMER L.L.P.

/s/ Kristopher S. Pre
By: _______________________
Kristopher S. Pre, Esq.
Nevada Bar No. 14106
Peter C. Wetherall, Esq.
Nevada Bar No. 4414
Elizabeth S. Carmona, Esq.
Nevada Bar No. 14687
NEVADA LEGAL SERVICES, INC.
701 E. Bridger Avenue, Suite 400
Las Vegas, Nevada 89101
Attorneys for Plaintiff Peggy Thornton

/s/ Kelly H. Dove
By: _______________________
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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Kelly H. Dove, Esq.
Nevada Bar No. 10569
Gil Kahn
Nevada Bar No. 14220
SNELL & WILMER L.L.P.
3883 Howard Hughes Parkway
Suite 1100
Las Vegas, NV 89169
Attorneys for Defendants Apartment
Management Consultants, LLC and Rene
Richardson

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ORDER

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IT IS SO ORDERED.
DATED: this 20th day of February, 2024.

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UNITED STATES DISTRICT COURT

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