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: 954-343-5624 [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 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 ORDER TO v. EXTEND DEADLINE TO FILE REPLY 25 IN SUPPORT OF MOTION FOR REED HEIN & ASSOCIATES, LLC d/b/a PROTECTIVE ORDER [ECF #404] 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 (“Diamond”), , Defendant Schroeter Goldmark & Bender, P.S. (“SGB”), and Defendant Reed Hein & Associates dba Timeshare Exit Team (“TET”) hereby stipulate to extend the deadlines for Diamond to file its Reply in support of its Motion for Protective Order (the “Motion”) [ECF #404], currently set for April 7, 2021 (SGB), and April 8, 2021 (TET), for a period of nine (9) and eight (8) days, respectively, through April 16, 2021, and as grounds state as follows: 1. Diamond filed the Motion on March 4, 2021.

2. The Parties stipulated to extend SGB’s and TET’s deadlines to respond to the Motion through April 8, 2021.

3. SGB filed its response to the Motion on April 1, 2021.

4. TET filed its response to the Motion on April 2, 2021.

5. As the Court is aware, Diamond is currently in the process of taking Depositions on Written Questions of the Identified Owners, which is taking a substantial amount of time for all parties.

6. In addition, the Parties, particularly Diamond and TET, are currently working to revolve various time-sensitive issues related to the DWQs of the Identified Owners.

7. In order to adequately reply to SGB and TET’s responses, and to harmonize the reply deadlines relative to both SGB and TET’s responses, the Parties have agreed to extend Diamond’s deadline to file its Reply in support of the Motion SGB’s Motion, and the issues || presented therein, the Diamond and SGB agree that Diamond’s deadline to file its response || should be extend through April 16, 2021.

3 8. 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.

6 Dated this 5th day of April, 2021.

7 || GREENSPOON MARDER LLP 8 LIPSON NEILSON, P.C.

9 /s/ Phillip A. Silvestri, Esq. /s/ Megan H. Thongham, Esq.

PHILLIP A. SILVESTRI, ESQ. JOSEPH P. GARIN, ESQ.

10 |) Nevada Bar No. 11276 Nevada Bar No. 6653 ¥ ll 3993 Howard Hughes Parkway, Suite 400 MEGAN H. THONGHAM, ESQ.

Las Vegas, NV 89169 Nevada Bar No. 12404 12 9900 Covington Cross Drive, Suite 120 = Attorneys for Plaintiff Las Vegas, NV 89144-7052 Z 13 || Diamond Resorts U.S. Collection Development, LLC Attorneys for Defendant SGB Pes 15 GORDON REES SCULLY MANSUKHANI, LLP /s/ David T. Gluth, Esq. = 17 ROBERT S. LARSEN, ESQ.

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

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

20 Nevada Bar No. 13285 300 South 4" Street, Suite 1550 21 Las Vegas, Nevada 89101 Attorneys for TET RRES 25 IT IS SO ORD Ee ° ee” 26 J efasge oF 2 og fee ee UNITED STATES MAGISTRATE JUDGE 28 DATED: 49-2021 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 5th day of April, 2021. 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