Filed: Jul. 03, 2019
Latest Update: Jul. 03, 2019
Summary: UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO MOTION FOR SUMMARY JUDGMENT (First Request) GLORIA M. NAVARRO , Chief District Judge . COMES NOW, Defendants, LAS VEGAS DEVELOPMENT GROUP, LLC; LAS VEGAS DEVELOPMENT, LLC; and LVDG, LLC, and hereby present their unopposed motion to extend the time in which they may respond to the Plaintiff's pending Motion for Summary Judgment, stating as follows: 1. On June 10, 2019, Plaintiffs filed a Motion for Summary Judgment herein [ECF #41]. A response
Summary: UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO MOTION FOR SUMMARY JUDGMENT (First Request) GLORIA M. NAVARRO , Chief District Judge . COMES NOW, Defendants, LAS VEGAS DEVELOPMENT GROUP, LLC; LAS VEGAS DEVELOPMENT, LLC; and LVDG, LLC, and hereby present their unopposed motion to extend the time in which they may respond to the Plaintiff's pending Motion for Summary Judgment, stating as follows: 1. On June 10, 2019, Plaintiffs filed a Motion for Summary Judgment herein [ECF #41]. A response ..
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UNOPPOSED MOTION TO EXTEND TIME TO RESPOND TO MOTION FOR SUMMARY JUDGMENT
(First Request)
GLORIA M. NAVARRO, Chief District Judge.
COMES NOW, Defendants, LAS VEGAS DEVELOPMENT GROUP, LLC; LAS VEGAS DEVELOPMENT, LLC; and LVDG, LLC, and hereby present their unopposed motion to extend the time in which they may respond to the Plaintiff's pending Motion for Summary Judgment, stating as follows:
1. On June 10, 2019, Plaintiffs filed a Motion for Summary Judgment herein [ECF #41]. A response to said Motion was due on July 1, 2019.
2. Defendants' counsel had expected to complete the Opposition to the Motion for Summary Judgment prior to the due date. However, a number of other matters came up that made doing so impossible, including numerous other pending legal matters and family obligations associated with Independence Day holiday. In addition, Defendants' counsel hopes to discuss settlement and potentially narrow the issues at hand.
3. Late in the day on July 1, 2019, Defendants' counsel sent an email to Plaintiffs' counsel requesting a 2 week extension of time until July 15, 2019, in which to respond to the pending Motion, together with a proposed stipulation to extend time. Kelly Dove, Esq., counsel for Federal National Mortgage Association, responded relatively immediately with her client's consent to the proposed stipulation.
4. John Tennert, Esq., counsel for Federal Housing Finance Agency, and John Maddock, III, Esq., counsel for Federal Home Loan Mortgage Corporation, responded to counsel's email on July 2, 2019, advising that while they do not oppose the requested extension, they feel that they cannot now so stipulate since the original deadline has passed. Both Mr. Tennert and Mr. Maddock advised that they will not oppose the instant Motion.
5. Defendants' counsel respectfully submits that the failure to submit a stipulation or motion in advance of the existing deadline constitutes excusable neglect under the circumstances herein.
6. This Motion is made in good faith and not for purpose of delay.
NOW THEREFORE, Defendant, Thunder Properties, Inc., respectfully requests that this Court extend the time in which it may respond to Plaintiffs' pending Motion for Summary Judgment [ECF #41] until July 15, 2019.
IT IS SO ORDERED.
