Diamond Resorts International, Inc. v. Reed Hein & Associates, LLC

1 Jeffrey Backman, Esq. (admitted Pro Hac Vice) Michelle Durieux, Esq. (admitted Pro Hac Vice) GREENSPOON MARDER LLP East Broward Blvd., Ste. 1800 Fort Lauderdale, FL 33301 Tel: 954 491-1120 Facsimile: 954-343-6958 [email protected] [email protected] [email protected] Phillip A. Silvestri, Esq.

Nevada Bar No. 11276 GREENSPOON MARDER LLP 3993 Howard Hughes Parkway, Ste. 400 Las Vegas, NV 89169 Tel: 702-978-4249 Fax: 954-333-4256 [email protected] Kimberly Maxson-Rushton 675 Nevada Bar No. 5065 Gregory Kraemer COOPER LEVENSON, P.A.

3016 W. Charleston Blvd., #195 Las Vegas, NV 89102 T: (702) 366-1125 F: (702) 366-1857 [email protected] [email protected] Attorneys for Plaintiff UNITED STATES DISTRICT COURT DISTRICT OF NEVADA DIAMOND RESORTS U.S. COLLECTION Case No.: 2:17-cv-03007-APG-VCF DEVELOPMENT, LLC, a Delaware Limited Liability Company, Plaintiff, STIPULATION AND [PROPOSED] v. ORDER TO EXTEND DEADLINE TO 25 FILE REPLY IN SUPPORT OF MOTION REED HEIN & ASSOCIATES, LLC d/b/a TO COMPEL [ECF #284] TIMESHARE EXIT TEAM, a Washington Limited Liability Company; BRANDON REED, [First Request] an individual and citizen of the State of Washington; TREVOR HEIN, an individual and citizen of Canada; THOMAS PARENTEAU, an Washington; HAPPY HOUR MEDIA GROUP, L ML IC TC, a H W ELa Lsh Rin .g Sto Un S L Si Mm Aite Nd , L Ei Sa Qbi .l i dty /b C /ao Tm Hp Ean y; LAW OFFICES OF MITCHELL REED SUSSMAN & ASSOCIATES, an individual and citizen of the State of California; SCHROETER, GOLDMARK & BENDER, P.S., a Washington Professional Services Corporation; and KEN B.

6 PRIVETT, ESQ., a citizen of the State of Oklahoma, Defendants.

Pursuant to LR IA 6-1 and Fed. R. Civ. P. 6(b)(1)(A) (“FRCP”), Plaintiff Diamond Resorts U.S. Collection Development, LLC (“Plaintiff”), and Defendant Reed Hein & Associates d/b/a/ Timeshare Exit Team (“Defendant”) hereby stipulate to extend Plaintiff’s deadline to file a Reply in support of Plaintiff’s Motion to Compel [ECF #284] (the “Motion”), currently set for September 18, 2020, until October 2, 2020, and as grounds state as follows: 1. Plaintiff filed the Motion on August 19, 2020.

2. Defendant filed its Opposition on September 11, 2020, after a brief extension to its response deadline.

3. Counsel for Plaintiff is concurrently in the process of drafting is Reply in Support of its Motion to Overrule SGB’s Privilege Claims, which is a fundamental issue in this litigation.

4. Additionally, Defendant’s Opposition raises several points related to documents that have been produced, but have not been specifically identified by bates reference. Counsel for Defendant has agreed to provide Plaintiff with specific references to the relevant production, however this will not be available prior to the current filing deadline.

5. In order to adequately respond to Defendant’s Opposition, and the issues presented therein, the Parties agree that Plaintiff’s deadline to file its Reply in support of the Motion be extended two (2) weeks, up to and including October 2, 2020 /// /// /// 1 6. This is the Parties’ first request for extension of this deadline, and it is not || intended to cause any delay or prejudice to any party. Defendant does not object to the requested || extension.

4 Dated this 17th day of September, 2020 GREENSPOON MARDER, LLP GORDON REES SCULLY 6 MANSUKHANI, LLP || 4s/ Phillip A. Silvestri /s/ Dione C. Wrenn PHILLIP A. SILVESTRI, ESQ. ROBERT S. LARSEN, ESQ.

8 || Nevada Bar No. 11276 Nevada Bar No. 7785 3993 Howard Hughes Parkway, Suite 400 DAVID T. GLUTH, II, ESQ.

Las Vegas, NV 89169 Nevada Bar No. 10596 || Attorneys for Plaintiff DIONE C. WRENN, ESQ.

Diamond Resorts Corporation Nevada Bar No. 13285 300 South 4" Street, Suite 1550 Las Vegas, Nevada 89101 EB 13 Attorneys for Defendants Reed Hein & Associates, LLC dba Timeshare 14 Exit Team, Brandon Reed, Trevor Hein, 2 Thomas Parenteau, and Happy Hour Media Eas 15 Group, LLC ERE 16 E17 18 Daas ITS 50 ORDER ey 20 UNITED STATES MAGISTRATE JUDGE 9-18-2020 2 DATED: 1 CERTIFICATE OF SERVICE 2 I HEREBY CERTIFY that I electronically filed the foregoing with the Clerk of the Court by using the CM/ECF system on this 17th day of September 2020. I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified on the Court’s Service List via transmission of Notices of Electronic Filing generated by CM/ECF. For any counsel or parties who are not are not authorized to receive Notices of Electronic Filing electronically, I certify that I served those parties via First Class U.S. Mail. /s/ Phillip A. Silvestri An employee of Greenspoon Marder LLP