Hillcrest Investments, Ltd. et al v. Chicago Title Insurace Company et al

Filing 36

ORDER Granting 35 Stipulation to Extend Time. Quail Valley Water District answer due twenty-one (21) days after entry of this Order. Signed by Magistrate Judge Cam Ferenbach on 11/16/2022. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:22-cv-00406-RFB-VCF Document 36 Filed 11/16/22 Page 1 of 4

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Daniel N. Raytis, California SBN 218374
[e-mail]
BELDEN BLAINE RAYTIS, LLP
5016 California Avenue, Suite 3
Bakersfield, California 93309
Telephone: [phone]
Facsimile: [phone]
Attorneys for Defendant
Quail Valley Water District

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
HILLCREST INVESTMENTS, LTD., a
foreign corporation; HILLCREST
PROJECTS, LLC., a foreign limited liability
company;

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Plaintiffs,
v.

Case No. 2:22-cv-00406-RFB-VCF
STIPULATION AND ORDER TO EXTEND
TIME FOR DEFENDANT TO RESPOND TO
COMPLAINT
(Sixth Request)

CHICAGO TITLE INSURANCE
COMPANY, a foreign entity; QUAIL
VALLEY WATER DISTRICT, a foreign
entity; 11239, LLC, a foreign entity;
R.A.M.M. CORP., a Nevada Corporation;
Defendants.

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Defendant Quail Valley Water District (“Defendant”), by and through its counsel of record,
Daniel N. Raytis, Esq. of Belden Blaine Raytis, LLP (admitted pro hac vice), and Plaintiffs Hillcrest
Investments, Ltd. and Hillcrest Projects, LLC (“Plaintiffs”), by and through their counsel of record,
Mitchell S. Bisson, Esq., hereby jointly submit this stipulation and order to extend Defendant’s
deadline to file its response to the Complaint (ECF No. 1, served on April 20, 2022), to twenty-one
(21) days after entry of this Order.
This is the Parties’ sixth and final request for an extension of Defendant’s response deadline.
Plaintiffs and Defendant remain engaged in good faith resolution discussions. This Stipulation is for

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STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT TO RESPOND TO COMPLAINT

Case 2:22-cv-00406-RFB-VCF Document 36 Filed 11/16/22 Page 2 of 4

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the purpose of facilitating efforts related thereto, and is not intended to cause any delay or prejudice

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to any party.

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Moreover, Defendant is an out-of-state entity. Defendant’s counsel was permitted to appear

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pro hac vice in this matter by an Order of the Court on June 15, 2022. Additionally, Plaintiffs and

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their representatives reside and are located in different areas throughout both the United States and

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Canada. Thus, the parties request this final extension in order to allow Plaintiffs and Defendant

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sufficient time to obtain necessary documents, materials, and information relevant to Plaintiffs’

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claims alleged against Defendant in order to respond to the Complaint or finalize resolution of the

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same. The Parties represent that they intend to work in good faith with each other in order to

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hopefully resolve this dispute prior to the pleading deadline. Nothing herein shall serve to waive or

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relinquish any right held by Defendant to file any necessary responsive pleading or motion to address

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Plaintiff’s Complaint at or before the responsive pleading deadline reset pursuant to this Joint

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Stipulation and this Court’s Order.

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Dated: November 16, 2022

BELDEN BLAINE RAYTIS, LLP

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By: /s/Daniel N. Raytis
DANIEL N. RAYTIS
Attorneys for Defendant Quail Valley
Water District

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THE LAW OFFICES OF MITCHELL
S. BISSON

Dated: November 16, 2022

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By: /s/Mitchell S. Bisson
MITCHELL S. BISSON, ESQ.
Attorney for Plaintiffs

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STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT TO RESPOND TO COMPLAINT

Case 2:22-cv-00406-RFB-VCF Document 36 Filed 11/16/22 Page 3 of 4

ORDER

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Based upon the stipulation of the parties, and good cause appearing,

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IT IS SO ORDERED.

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Dated this 16th day of November, 2022.

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No further extensions
will be granted.

UNITED STATES MAGISTRATE JUDGE
Case No. 2:22-cv-00406-RFB-VCF

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STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT TO RESPOND TO COMPLAINT

Case 2:22-cv-00406-RFB-VCF Document 36
35 Filed 11/16/22 Page 4 of 4

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Case No. 22:cv-00406

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PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF KERN

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I am employed in the County of Kern, State of California. I am over the age of eighteen

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years and not a party to the within action; my business address is 5016 California Ave., Suite 3,

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Bakersfield, CA 93309. My email address is [e-mail].

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On November 16, 2022, I served the following document(s) described as
STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT TO
RESPOND TO COMPLAINT (Sixth Request)

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10 on the interested parties in this action via electronic service through the Court’s Electronic
11 File/Service Program.
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Mitchell S. Bisson, Esq.
Law Offices of Mitchell S. Bisson
911 N. Buffalo Drive, Suite 201
Las Vegas, CA 89128
[e-mail]
Natalie C. Lehman, Esq.
Fidelity National Law Group
8363 W. Sunset Road, Suite 120
Law Vegas, NV 89113
[e-mail]

Attorney for Plaintiffs Hillcrest
Investments, LTD

Attorneys for Defendant Chicago
Title Insurance Company

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Executed on November 16, 2022, at Bakersfield, California.

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I declare under penalty of perjury under the laws of the State of California that the

21 foregoing is true and correct.
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Heather McCoy