PennyMac Loan Services, LLC v. Townhouse Greens Association, Inc. et al

Filing 32

ORDER granting ECF No. 29 Stipulation : Response to ECF No. 21 MOTION to Dismiss due by 10/10/2016. Signed by Judge Miranda M. Du on 10/4/2016. (Copies have been distributed pursuant to the NEF - DRM)

Case 3:16-cv-00504-MMD-VPC Document 29 Filed 10/03/16 Page 1 of 2

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ARIEL E. STERN, ESQ.
Nevada Bar No. 8276
VATANA LAY, ESQ.
Nevada Bar No. 12993
1160 Town Center Drive, Suite 330
Las Vegas, Nevada 89144
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiff PennyMac Loan
Services, LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

AKERMAN LLP

1160 TOWN CENTER DRIVE, SUITE 330
LAS VEGAS, NEVADA 89144
TEL.: [phone] – FAX: [phone]

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PENNYMAC LOAN SERVICES, LLC,

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3:16-cv-00504-MMD-VPC

Plaintiff,

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Case No.:

vs.
TOWNHOUSE GREENS ASSOCIATION, INC.;
THUNDER PROPERTIES, INC.; GAYLE A.
KERN, LTD d/b/a KERN & ASSOCIATES,
LTD,

AMENDED STIPULATION AND ORDER
TO EXTEND TIME TO FILE A RESPONSE
TO THUNDER PROPERTIES, INC.'S
MOTION TO DISMISS
(FIRST REQUEST)

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Defendants.

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The parties respectfully submit the following Stipulation to allow Defendant Pennymac Loan

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Services, LLC (Pennymac) until October 10, 2016 to file a response to Thunder Properties, Inc.'s

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(Thunder) motion to dismiss [ECF 21] filed on September 13, 2016.

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Pennymac requests additional time to respond to Thunder's motion to dismiss to allow

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Pennymac time to confirm the bases for the court's jurisdiction over Thunder. Counsel for Pennymac

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has been investigating Thunder's jurisdiction contentions but has been unable to complete the

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investigation due to prior commitments with multiple depositions and hearings that were set prior to

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Thunder's filing of its motion to dismiss. The additional time will help provide adequate time for

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Pennymac to fully brief Thunder's motion to dismiss.

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Case 3:16-cv-00504-MMD-VPC Document 29 Filed 10/03/16 Page 2 of 2

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Pennymac's response to Thunder's motion to dismiss was due on September 30, 2016.

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Pennymac originally filed a stipulation for additional time to respond to Thunder's motion to dismiss

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on September 30, 2016 [ECF 27]. However, the Court rejected the stipulation due to a Pennymac's

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inadvertent failure to comply with LR IA 6-1. As such, the filing of this amended stipulation to extend

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the time for Pennymac to respond to Thunder's motion to dismiss after the date the response was due

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to excusable neglect.

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This is the first request for an extension of this deadline, and is not intended to cause any delay
or prejudice to any party.
DATED this 3rd day of October, 2016.

AKERMAN LLP

1160 TOWN CENTER DRIVE, SUITE 330
LAS VEGAS, NEVADA 89144
TEL.: [phone] – FAX: [phone]

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AKERMAN LLP

ROGER P. CROTEAU & ASSOCIATES, LTD.

/s/ Vatana Lay_________________
ARIEL E. STERN, ESQ.
Nevada Bar No. 8276
VATANA LAY, ESQ.
Nevada Bar No. 12993
AKERMAN LLP
1160 Town Center Drive, Suite 330
Las Vegas, Nevada 89144

/s/ Timothy Rhoda______________
ROGER P. CROTEAU, ESQ.
Nevada Bar No. 4958
TIMOTHY RHODA, ESQ.
Nevada Bar No. 7878
Roger P. Croteau & Associates, Ltd.
9120 West Post Road, Suite 100
Las Vegas, Nevada 89148

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Attorneys for Plaintiff Pennymac Loan
Services, LLC

Attorneys for Defendant
Association, Inc.

Townhouse

Greens

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IT IS SO ORDERED:

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__________________________________________
UNITED STATES DISTRICT COURT JUDGE
October 4, 2016
DATED: _________________________________

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