Opinion
2:18-cv-01919-RFB-BNW
11-07-2022
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, S.C.
Robert G. Bernhoft
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.
Blakeley E. Griffith
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
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 one-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' second 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 obtained an extension from November 2, 2022, the initial deadline, to November 9, 2022. (ECF No. 264.) The Parties request another one-week extension until November 16, 2022.
The reason for the extension is the Parties discussed their understanding of the Order on November 1, 2022, after Plaintiffs' counsel returned from multiple trips. The Parties have come to an understanding on the parameters of the document production, which differed from BANA's initial understanding. For this reason, BANA needs additional time to finalize the document production.
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 16, 2022.
IT IS SO STIPULATED.
IT IS SO ORDERED.