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Securities and Exchange Commission v. Fujinaga, 2:13-cv-01658-JCM-CWH. (2018)

Court: District Court, D. Nevada Number: infdco20180116c10 Visitors: 1
Filed: Jan. 12, 2018
Latest Update: Jan. 12, 2018
Summary: AMENDED STIPULATION AND ORDER TO EXTEND HELEN TANG'S DEADLINE TO FILE A RESPONSE TO THE RECEIVER'S MOTION (FIRST REQUEST) C.W. HOFFMAN, JR. , Magistrate Judge . Helen Tang(" Ms. Tang "), by and through her counsel Daniel W.Glasser of the law firm of Chipman Glasser, LLC on the one hand, and Robb Evans & Associates LLC, as receiver (the " Receiver ") by and through its counsel, Michael F. Lynch of the Lynch Law Practice, PLLC on the other hand, hereby stipulate to the following: 1. That th
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AMENDED STIPULATION AND ORDER TO EXTEND HELEN TANG'S DEADLINE TO FILE A RESPONSE TO THE RECEIVER'S MOTION

(FIRST REQUEST)

Helen Tang("Ms. Tang"), by and through her counsel Daniel W.Glasser of the law firm of Chipman Glasser, LLC on the one hand, and Robb Evans & Associates LLC, as receiver (the "Receiver") by and through its counsel, Michael F. Lynch of the Lynch Law Practice, PLLC on the other hand, hereby stipulate to the following:

1. That the Receiver filed its Motion for Order Authorizing Directing, and Requiring Rabohank, N.A. and Helen Tang to Immediately Turn Over to the Receiver All Proceedsfrom the Sale ofOne Stop Pharmacy, on December 20, 2017 (ECF No.464) (the "Motion"). The Receiver filed and served upon Ms. Tang by mail, its Notice of Motion and Opportunity to Object on December 21, 2017. (ECF Nos. 466, 468);

2. That Ms.Tang's response to the Motion was due January 8, 2018. (Fed. R. Civ. P. 6(d) and LR 7-2);

3. That the parties' original Stipulation and Order filed January 8, 2018 (ECF No. 472) mistakenly proposed the court. holiday January 15 as the deadline, and thus the parties hereby submit this Amended Stipulation and Order stipulating to a January 16, 2018 deadline;

4. That Ms. Tang requires additional time beyond the original deadline in light of tilt following: (a) the Receiver's Motion was filed just before the year-end holidays, during which time the undersigned attorneys' and their staffs' regular work schedules were altered and reduce( in advance where feasible, (b) Ms. Tang expended reasonable efforts to retain counsel and retained Mr. Glasser on January 5, 2018, and (c) Mr. Glasser has thereby had insufficient lime to become fully familiar with the issues raised in the Motion and prepare a substantive response;

5. That it is appropriate under the circumstances to allow Ms. Tang's abovereferenced counsel up to and including Tuesday, January 16, 2018 to file a response to the Motion on behalf of Ms. Tang; and

6. That, subject to entry of the order proposed below, the deadline to respond to the Receiver's Motion shall be extended for Ms. Tang only, as follows:

Current Deadline Proposed Deadline Ms. Tang's deadline to file a response to the 01/08/2018 01/16/2018 Receiver's Motion

IT IS SO ORDERED.

This order supersedes the parties' stipulation at #472, which is hereby DENIED as MOOT.

Source:  Leagle

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