Opinion
2:22-cv-00406-RFB-VCF
11-16-2022
HILLCREST INVESTMENTS, LTD., a foreign corporation; HILLCREST PROJECTS, LLC., a foreign limited liability company; Plaintiffs, v. 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
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
STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT TO RESPOND TO COMPLAINT (SIXTH 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 twenty-one (21) days after entry of this Order.
This is the Parties' sixth and final request for an extension of Defendant's response deadline. Plaintiffs and Defendant remain engaged in good faith resolution discussions. This Stipulation is for the purpose of facilitating efforts related thereto, and is not intended to cause any delay or prejudice to any party.
Moreover, 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. Additionally, Plaintiffs and their representatives reside and are located in different areas throughout both the United States and Canada. Thus, the parties request this final extension in order to allow Plaintiffs and Defendant sufficient time to obtain necessary documents, materials, and information relevant to Plaintiffs' claims alleged against Defendant in order to respond to the Complaint or finalize resolution of the same. The Parties represent that they intend to work in good faith with each other in order to hopefully resolve this dispute prior to the pleading deadline. Nothing herein shall serve to waive or relinquish any right held by Defendant to file any necessary responsive pleading or motion to address Plaintiff's Complaint at or before the responsive pleading deadline reset pursuant to this Joint Stipulation and this Court's Order.
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 November 16, 2022, I served the following document(s) described as
STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT TO RESPOND TO COMPLAINT (Sixth Request)on the interested parties in this action via electronic service through the Court's Electronic File/Service Program.
| Mitchell S. Bisson, Esq. Law Offices of Mitchell S. Bisson 911 N. Buffalo Drive, Suite 201 Las Vegas, CA 89128 mbisson@bissonlegal.com | Attorney for Plaintiffs Hillcrest Investments, LTD |
| Natalie C. Lehman, Esq. Fidelity National Law Group 8363 W. Sunset Road, Suite 120 Law Vegas, NV 89113 Natalie.lehman@fnf.com | Attorneys for Defendant Chicago Title Insurance Company |
Executed on November 16, 2022, at Bakersfield, California.
I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct.
Heather McCoy