Filed: Aug. 30, 2016
Latest Update: Aug. 30, 2016
Summary: EX PARTE MOTION FOR EXTENSION OF TIME FOR DITECH FINANCIAL LLC TO FILE REPLY IN SUPPORT OF ITS MOTION FOR SANCTIONS (FIRST REQUEST) C.W. HOFFMAN, Jr. , District Judge . Defendant Ditech Financial LLC, fka Green Tree Servicing, LLC, a Delaware limited liablity company (" Ditech " or " Defendant ") hereby submits this Ex Parte Motion for Extension of Time for Ditech Financial LLC to file Reply in Support of its Motion for Sanctions. On July 27, 2016 Ditech filed its Motion for Sanction
Summary: EX PARTE MOTION FOR EXTENSION OF TIME FOR DITECH FINANCIAL LLC TO FILE REPLY IN SUPPORT OF ITS MOTION FOR SANCTIONS (FIRST REQUEST) C.W. HOFFMAN, Jr. , District Judge . Defendant Ditech Financial LLC, fka Green Tree Servicing, LLC, a Delaware limited liablity company (" Ditech " or " Defendant ") hereby submits this Ex Parte Motion for Extension of Time for Ditech Financial LLC to file Reply in Support of its Motion for Sanctions. On July 27, 2016 Ditech filed its Motion for Sanctions..
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EX PARTE MOTION FOR EXTENSION OF TIME FOR DITECH FINANCIAL LLC TO FILE REPLY IN SUPPORT OF ITS MOTION FOR SANCTIONS
(FIRST REQUEST)
C.W. HOFFMAN, Jr., District Judge.
Defendant Ditech Financial LLC, fka Green Tree Servicing, LLC, a Delaware limited liablity company ("Ditech" or "Defendant") hereby submits this Ex Parte Motion for Extension of Time for Ditech Financial LLC to file Reply in Support of its Motion for Sanctions.
On July 27, 2016 Ditech filed its Motion for Sanctions (ECF No. 22). On August 3, 2016 Plaintiff and Ditech entered into a stipulation whereby Plaintiff's Opposition to the Motion for Sanctions was continued to August 22, 2016 (ECF No. 24). On Monday, August 22, 2016, Plaintiff filed its Opposition to the Motion (ECF No. 28). Ditech's Reply in support of the Motion is due on September 1, 2016. Ditech respectfully requests a one week extension to file its Reply. This is the first request for an extension.1 This request is not being made in bad faith, but due to previously scheduled travel of Ditech's counsel and her workload upon return from that travel. See Declaration of Blakeley E. Griffith, attached hereto as Exhibit 1. Ditech respectfully requests that the Court grant the Motion and allow Ditech to file its Reply on September 8, 2016.
IT IS SO ORDERED.
ORDER
IT IS SO ORDERED.
EXHIBIT 1
Declaration of Blakeley E. Griffith in Support of Ex Parte Motion for Extension of Time for Ditech Finartcial LLC to File Reply in Support of its Motion for Sanctions
Amy F. Sorenson, Esq.
Nevada Bar No. 12495
Blakeley E. Griffith, Esq.
Nevada Bar No. 12386
SNELL & WILMER L.L.P.
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, NV 89169
Telephone: (702) 784-5200
Facsimile: (702) 784-5252
Email: asorenson@swlaw.com
bgriffith@swlaw.com
Attorneys for Ditech Financial LLC
fka Green Tree Servicing, LLC a
Delaware limited liability company
IN THE UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
YUICHI MIYAYAMA, individual, Case No. 2:16-CY-00413-JAD-CWH
Plaintiff,
vs.
DECLARATION OF BLAKELEY E.
GRIFFITH IN SUPPORT OF EX PARTE
QUALITY LOAN SERVICE MOTION FOR EXTENSION OF TIME
CORPORATION, a California corporation; FOR DITECH FINANCIAL LLC TO
DITECH FINANCIAL LLC f/k/a GREEN FILE REPLY IN SUPPORT OF ITS
TREE SERVICING LLC, a Delaware MOTION FOR SANCTIONS
limited liability company; ROES 1-5; and,
DOES 1-5, inclusive,
Defendants.
I, Blakeley Griffith, declare as follows:
1. I have personal knowledge of all matters set forth herein, except for those matters stated to be based upon information and belief. If called to do so, I would competently and truthfully testify to all matters set forth herein, except for those matters stated to be based upon information and belief.
2. I make this Declaration in support of Ditech Financial LLC's Ex Parte Motion for Extension of Time for Ditech Financial LLC to file Reply in Support of its Motion for Sanctions (the "Motion").
3. I am an attorney licensed to practice law in the State of Nevada with the law firm of Snell & Wilmer L.L.P., counsel for Ditech Financial LLC in the above-entitled matter.
4. The request for an extension of time is made in good faith and not for the purposes of delay.
5. The Motion for Sanctions was filed on July 27, 2016. (ECF No. 22).
6. The Opposition to the Motion for Sanctions was filed on August 22, 2016.1 (ECF No. 28).
7. The Reply in support of the Motion for Sanctions is due on September 1, 2016, which is ten days after the Opposition was filed.
8. Good cause exists for the extension of time as I had a previously scheduled trip the weekend of August 26, 2016, which could not be moved. I did not return to the office until August 30, 2016. Due to my workload the week of August 22, 2016, I was unable to complete the Reply in support of the Motion for Sanctions prior to this travel.
9. As the deadline for the Motion for Sanctions is quickly approaching, I am requesting a short extension of time (one week) to submit the Reply for the Court's consideration.
