Opinion
2:18-cv-01919-RFB-BNW
10-28-2022
RICHARD ZEITLIN, ADVANCED TELEPHONY CONSULTANTS, MRZ MANAGEMENT, LLC, DONOR RELATIONS, LLC, TPFE, INC., AMERICAN TECHNOLOGY SERVICES, COMPLIANCE CONSULTANTS, CHROME BUILDERS CONSTRUCTION, INC., and UNIFIED DATA SERVICES, Plaintiffs, v. BANK OF AMERICA, N.A., and JOHN and JANE DOES 1-100, Defendants.
THE BERNHOFT LAW FIRM, SC Robert G. Bernhoft, Esq. Admitted Pro Hac Vice Wisconsin Bar No. 1032777 Thomas E. Kimble, Esq. Admitted Pro Hac Vice Illinois Bar No. 6257935 Daniel James Treuden, Esq. Wisconsin Bar No. 1052766, Joel F. Hansen, Esq. Nevada Bar No. 1876 Hansen & Hansen, LLC Attorneys for Plaintiffs SNELL & WILMER L.L.P. Amy F. Sorenson, Esq. Nevada Bar No. 12495 Blakeley E. Griffith, Esq. Nevada Bar No. 12386 Holly E. Cheong, Esq. Nevada Bar No. 11936 Attorneys for Defendant Bank of America, N.A.
THE BERNHOFT LAW FIRM, SC Robert G. Bernhoft, Esq. Admitted Pro Hac Vice Wisconsin Bar No. 1032777 Thomas E. Kimble, Esq. Admitted Pro Hac Vice Illinois Bar No. 6257935 Daniel James Treuden, Esq. Wisconsin Bar No. 1052766, Joel F. Hansen, Esq. Nevada Bar No. 1876 Hansen & Hansen, LLC Attorneys for Plaintiffs
SNELL & WILMER L.L.P. Amy F. Sorenson, Esq. Nevada Bar No. 12495 Blakeley E. Griffith, Esq. Nevada Bar No. 12386 Holly E. Cheong, Esq. Nevada Bar No. 11936 Attorneys for Defendant Bank of America, N.A.
STIPULATION AND ORDER TO EXTEND TIME TO PRODUCE DOCUMENTS IN RESPONSE TO COURT'S ORDER PARTIALLY GRANTING PLAINTIFFS' MOTION TO COMPEL, ECF NO. 257
(FIRST REQUEST)
Plaintiffs Richard Zeitlin; Advanced Telephony Consultants; MRZ Management, LLC; Donor Relations, LLC; TPFE, Inc.; American Technology Services; Compliance Consultants; Chrome Builders Construction, Inc.; and Unified Data Services (the “Plaintiffs”) and Defendant Bank of America, N.A. (“BANA”), by and through their respective undersigned counsel of record, submit this Stipulation and Proposed Order for a 1-week extension of BANA's deadline to produce certain documents in response to this Court's Order partially granting Plaintiffs' Motion to Compel (ECF No. 257) (the “Order”). This is the Parties' first request for an extension of the production deadline for the Order and is not intended to cause any delay or prejudice to any party.
The Order was filed on October 3, 2022, and ordered BANA to produce certain documents within 30 days. (ECF No. 257 at 4:12.) The Parties request an extension from November 2, 2022, BANA's current deadline to produce documents, to November 9, 2022.
The reason for the extension is to give the Parties time to discuss their understanding of the Order as Plaintiffs' counsel just recently returned from an overseas trip.
IT IS HEREBY STIPULATED AND AGREED by and between the Parties that the time for BANA to produce documents pursuant to the Order is extended to and through November 9, 2022.
IT IS SO STIPULATED.
IT IS SO ORDERED.