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

1 ROBERT S. LARSEN, ESQ.

Nevada Bar No. 7785 2 DAVID T. GLUTH, II, ESQ.

Nevada Bar No. 10596 3 DIONE C. WRENN, ESQ.

Nevada Bar No. 13285 4 GORDON REES SCULLY MANSUKHANI, LLP

300 South 4th Street, Suite 1550 5 Las Vegas, Nevada 89101

Telephone: (702) 577-9300 6 Facsimile: (702) 255-2858

E-Mail: [email protected] 7 [email protected] [email protected] Attorneys for Defendants

9 Reed Hein & Associates, LLC dba Timeshare Exit Team,

Brandon Reed, Trevor Hein, Thomas Parenteau, and 10 Happy Hour Media Group, LLC 11 UNITED STATES DISTRICT COURT 12 DISTRICT OF NEVADA 13 DIAMOND RESORTS CORPORATION, a ) Case No.: 2:17-cv-03007-APG-VCF

Maryland corporation, ) 14 )

Plaintiffs, ) 15 ) STIPULATION AND ORDER

vs. ) REGARDING DEADLINE TO 16 ) FILE RESPONSE TO

REED HEIN & ASSOCIATES, LLC, d/b/a ) PLAINTIFF’S MOTION FOR 17 TIMESHARE EXIT TEAM, a Washington limited ) PROTECTIVE ORDER liability company; BRANDON REED, an individual ) 18 and citizen of the State of Washington; TREVOR ) [First Stipulation]

HEIN, an individual and citizen of Canada; ) 19 THOMAS PARENTEAU, an individual and citizen ) of the State of Washington; HAPPY HOUR MEDIA ) 20 GROUP, LLC, a Washington limited liability ) company; MITCHELL REED SUSSMAN, ESQ. ) 21 d/b/a THE LAW OFFICES OF MITCHELL REED )

SUSSMAN & ASSOCIATES, an individual citizen ) 22 of the State of California; SCHROETER, )

GOLDMARK & BENDER, P.S. A Washington ) 23 professional services corporation; and KEN B. )

PRIVETT, ESQ., a citizen of Oklahoma, ) 24 )

Defendants. ) 25 ) 26 Pursuant to Local Rules IA 6-1, IA 6-2, and 7-1, Plaintiff DIAMOND RESORTS U.S. 27 COLLECTION DEVELOPMENT, LLC (“Plaintiff”) and Defendant REED HEIN &

“Parties”) by and through their respective attorneys of record, hereby jointly stipulate as stated below.

4 STIPULATION 5 1. On March 4, 2021, Plaintiff filed a Motion for Protective Order related to the 6 deposition of the FRCP 30(b)(6) deposition of Plaintiff (the “Motion”). ECF No. 404. 7 2. TET Defendants served a joinder to the deposition notice and TET Defendants’ 8 counsel participated in the meet and confer conference regarding the topics. TET Defendants 9 advised Plaintiff that it would be joining in the briefing on the issues that could not be resolved. 10 3. The deadline for response or opposition to the Motion was March 18, 2021. 11 4. Plaintiff and SGB submitted a stipulation and order extending the deadline for the 12 response until April 1, 2021, which was granted by the court. ECF No. 406. 13 5. TET Defendants were not included in the prior stipulation so in an abundance of 14 caution are submitting its own stipulation for the court.

15 6. In order to adequately address and brief the issues presented in the Motion (ECF 16 No. 404), the Parties agree that TET Defendants deadline to respond to the Motion also be 17 extended up to and including April 1, 2021.

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7. 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. Plaintiff does not object to the requested extension.

4 Dated this 16th day of March, 2021.

GREENSPOON MARDER, LLP GORDON REES SCULLY 5 MANSUKHANI, LLP 6 || /s/ Phillip A. Silvestri /s/ David T. Gluth

PHILLIP A. SILVESTRI, ESQ. ROBERT S. LARSEN, ESQ. 7 || Nevada Bar No. 11276 Nevada Bar No. 7785

3993 Howard Hughes Parkway, Suite 400 DAVID T. GLUTH, I, ESQ. 8 ||Las Vegas, NV 89169 Nevada Bar No. 10596

DIONE C. WRENN, ESQ. 9 ||RICHARD W. EPSTEIN, ESQ. Nevada Bar No. 13285

Admitted Pro Hac Vice 300 South 4" Street, Suite 1550 10 || JEFFREY BACKMAN, ESQ. Las Vegas, Nevada 89101

Admitted Pro Hac Vice 11 |] MICHELLE E DURIEUX, ESQ. Attorneys for Defendants

Admitted Pro Hac Vice Reed Hein & Associates, LLC dba Timeshare 12 || 200 East Broward Blvd., Suite 1800 Exit Team, Brandon Reed, Trevor Hein,

B25 Fort Lauderdale, FL 33301 Thomas Parenteau, and Happy Hour Media aa 13 Group, LLC 2 Be Attorneys for Plaintiff

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ORDER

IT IS SO ORDERBB a ai aires as = = □□ □□ ig NITED STATES MAGISTRATE JUDGE

DATED: 3-16-2021