Goodwin et al v. Executive Trustee Services, LLC et al

Filing 529

ORDER. IT IS ORDERED, Defendants Countrywide Home Loans, Inc. and Wells Fargo Bank, N.A. 528 Motion for Extension of Time is GRANTED. Said defendants' shall file their replies to 507 and 508 Motions to Vacate Non-Foreclosure Stipulations on or before September 13, 2010. Signed by Judge Edward C. Reed, Jr on 8/24/2010. (Copies have been distributed pursuant to the NEF - KO)

Goodwin et al v. Executive Trustee Services, LLC et al

Doc. 529

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

Cynthia Alexander, Esq. (Nevada Bar No. 6718) Erica Stutman, Esq. (Nevada Bar No. 10794) SNELL & WILMER LLP 3883 Howard Hughes Pkwy, Suite 1100 Las Vegas, NV 89169 Telephone: [phone] Facsimile: [phone] Thomas M. Hefferon, Esq. (pro hac vice) Joseph F. Yenouskas, Esq. (pro hac vice) GOODWIN PROCTER LLP 901 New York Avenue, NW Washington, DC 20001 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Attorneys for Defendant Wells Fargo Bank, N.A.

UNITED STATES DISTRICT COURT DISTRICT OF NEVADA ALETA ROSE GOODWIN et al., Plaintiffs, vs. Case No. 3:09-cv-306-ECR-VPC

EMERGENCY UNOPPOSED MOTION FOR EXTENSION OF TIME FOR EXECUTIVE TRUSTEE SERVICES, LLC et COUNTRYWIDE HOME LOANS, INC. al., AND WELLS FARGO BANK, N.A. TO FILE REPLIES IN SUPPORT OF Defendants. THEIR MOTIONS TO VACATE NONFORECLOSURE STIPULATIONS (Third Request)1 ORDER GRANTING Pursuant to Local Rules 6-1 and 6-2, Defendant, Countrywide Home Loans, Inc. and Defendant Wells Fargo Bank, N.A. (collectively, "Defendants"), by and through their undersigned Counsel, move for a three (3) week extension of time, up through and including September 13, 2010, to file replies in support of their respective Motion to Vacate NonForeclosure Stipulations, which were filed May 19, 2010.
1

The first two requests for an extension were obtained by stipulation and order, as described below.
11911218.1

Dockets.Justia.com

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28

On May 19, 2010, Defendant Countrywide Home Loans, Inc. filed a Motion to Vacate Non-Foreclosure Stipulations (Doc. #508), and Defendant Wells Fargo Bank, N.A. also filed a Motion to Vacate Non-Foreclosure Stipulations (Doc. #507). Plaintiffs filed an Opposition to the motions on July 1, 2010. (Doc. #519). Defendants obtained a stipulated extension of time to file their respective replies until August 2, 2010 so that Defendants would have time to gather the facts and arguments needed to file reply briefs and to consider a proposal made by Plaintiffs about possible resolution of this dispute raised in the motions. (Doc. #521) Defendants obtained a second stipulated extension of time to file their respective replies until August 23, 2010 because the parties were in the process of discussing details of a stipulation that would informally resolve this dispute. (Doc. #524). The parties are still in the process of discussing details of a stipulation that would informally resolve this dispute. As both the Court's and the parties' resources will be preserved if the parties are able to agree upon a resolution, Defendants request an additional three week extension of time to file their respective replies, up through and including September 13, 2010. Plaintiffs' counsel has agreed to the extension. However, Defendants are filing this motion because Defendants' counsel has been unable to reach Plaintiffs' counsel to sign stipulations reflecting the extensions. Defendants' counsel has no reason to believe Plaintiffs oppose this requested extension. WHEREFORE, Defendants respectfully request that the Court grant this Emergency Unopposed Motion For Extension of Time For Countrywide Home Loans, Inc. and Wells Fargo Bank, N.A. To File Replies In Support of Their Motions To Vacate Nonforeclosure Stipulations, and order that Defendants' replies are due on or before September 13, 2010. Dated: August 23, 2010 Respectfully submitted, /s/ Erica Stutman Cynthia Alexander, Esq. (Nevada Bar No. 6718) Erica Stutman, Esq. (Nevada Bar No. 10794) SNELL & WILMER LLP
11911218.1

-2-

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28
11911218.1

3883 Howard Hughes Pkwy, Suite 1100 Las Vegas, NV 89169 Telephone: [phone] Facsimile: [phone] Thomas M. Hefferon, Esq. (pro hac vice) Joseph F. Yenouskas, Esq. (pro hac vice) GOODWIN PROCTER LLP 901 New York Avenue, NW Washington, DC 20001 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Attorneys for Defendant Wells Fargo Bank, N.A. __/s/ ARIEL E. STERN ____ ARIEL E. STERN, ESQ. #8276 JACOB BUNDICK, ESQ. # 9772 AKERMAN SENTERFITT LLP 400 South Fourth Street, Suite 450 Las Vegas, NV 89101 Tel: [phone] Fax: [phone] Thomas M. Hefferon, Esq. (pro hac vice) Joseph F. Yenouskas, Esq. (pro hac vice) GOODWIN PROCTER LLP 901 New York Avenue, NW Washington, DC 20001 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] Attorneys for Defendant Countrywide Home Loans, Inc. IT IS SO ORDERED:

_________________________________ UNITED STATES DISTRICT JUDGE August 24, 2010. DATED: August _____, 2010 August 24, 2010

-3-