Opinion
2:22-cv-00406-RFB-VCF
10-19-2022
HILLCREST INVESTMENTS, LTD., a foreign corporation; HILLCREST PROJECTS, LLC., a foreign limited liability company; Plaintiffs, CHICAGO TITLE INSURANCE COMPANY, a foreign entity; QUAIL VALLEY WATER DISTRICT, a foreign entity; 11239, LLC, a foreign entity; R.A.M.M. CORP., a Nevada Corporation; Defendants.
BELDEN BLAINE RAYTIS, LLP DANIEL N. RAYTIS Attorneys for Defendant Quail Valley Water District THE LAW OFFICES OF MITCHELL S. BISSON MITCHELL S. BISSON, ESQ. Attorney for Plaintiffs Natalie C. Lehmna, Esq. Fidlity National Law Group Attorneys for Defendant Chicago Title Insurance Company
BELDEN BLAINE RAYTIS, LLP
DANIEL N. RAYTIS
Attorneys for Defendant Quail Valley Water District
THE LAW OFFICES OF MITCHELL S. BISSON
MITCHELL S. BISSON, ESQ.
Attorney for Plaintiffs
Natalie C. Lehmna, Esq.
Fidlity National Law Group
Attorneys for Defendant Chicago Title Insurance Company
STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT TO RESPOND TO COMPLAINT (FIFTH REQUEST)
Defendant, Quail Valley Water District, (“Defendant”) by and through its counsel of record, Daniel N. Raytis, Esq., of Belden Blaine Raytis, LLP (admitted pro hac vice) and Plaintiffs, Hillcrest Investments, Ltd. and Hillcrest Projects, LLC (“Plaintiffs”), by and through their counsel of record, Mitchell S. Bisson, Esq., hereby jointly submit this stipulation and order to extend Defendant's deadline to file its response to the Complaint (ECF No. 1, served on April 20, 2022), to thirty (30) days after entry of this Order.
Defendant is an out-of-state entity. Defendant's counsel was permitted to appear pro hac vice in this matter by an Order of the Court on June 15, 2022.
This is the Parties' fifth joint request for an extension of this deadline and is not intended to cause any delay or prejudice to any party to this action. The Parties are currently in the process of attempting resolve this action prior to the filing of a responsive pleading. As such, the Parties request this extension in order to provide Defendant with additional time to obtain documents, materials and information relevant to Plaintiff's claims alleged against Defendant in order to respond to the Complaint and/or discuss resolution of the same. The extension would also result in significant saving of time, costs, and fees should resolution be reached, as well as promote efficiency and judicial economy.
ORDER
Based upon the stipulation of the parties, and good cause appearing, IT IS SO ORDERED.
PROOF OF SERVICE
STATE OF CALIFORNIA, COUNTY OF KERN
I am employed in the County of Kern, State of California. I am over the age of eighteen years and not a party to the within action; my business address is 5016 California Ave., Suite 3, Bakersfield, CA 93309. My email address is heather@bbr.law.
On October 18, 2022, I served the following document(s) described as on the interested parties in this action via electronic service through the Court's Electronic File/Service Program.