Shirehampton Drive Trust v. JP Morgan Chase Bank N.A.

1 || Kent F. Larsen, Esq.

5 Nevada Bar No. 3463 SMITH LARSEN & WIXOM || 1935 Village Center Circle Las Vegas, Nevada 89134 |! Tel.: (702) 252-5002 Fax: (702) 252-5006 Email: [email protected] || Attorneys for Defendant/Counterclaimant JPMorgan Chase Bank, N.A.

3 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA || SHIREHAMPTON DRIVE TRUST, CASE NO.: 2:16-cv-02276-RFB-EJY Plaintiff, V. a = 4 JPMORGAN CHASE BANK, NATIONAL | STIPULATION AND ORDER TO 2 < ASSOCIATION; MTC FINANCIAL INC. EXTEND DEADLINES TO FILE & & 15 || DBA TRUSTEE CORPS; and LOUISA SUPPLEMENTAL BRIEFS OAKENELL, RE: NOVEMBER 19, 2021 STATUS © GS 16 HEARING Z a "7 Defendants. < 2 (First Request) JPMORGAN CHASE BANK, N.A., 50 Counterclaimant, 21 Vv.

22 || SHIREHAMPTON DRIVE TRUST; DOES 33 1 through 10, inclusive; and ROE CORPORATIONS 1 through 10, inclusive, Counterdefendants.

27 Plaintiff Shirehampton Drive Trust (“Plaintiff”) and Defendants JPMorgan Chase Ban!

28 ||N.A. (“Chase”), by and through their respective counsel of record, hereby agree as follows: 1 1. On November 19, 2022, the Court held a status hearing regarding this matter light the Memorandum entered by the Ninth Circuit Court of Appeals in Case No. 19-17253 c October 18, 2020 (Docket No. 70).

5 2. After discussion at the status hearing, the Court directed Plaintiff and Chase 1 || submit supplemental briefs to address certain issues raised by the Ninth Circuit’s Memorandun 7 3. Plaintiff's counsel submitted his brief on December 20, 2021(Docket No. 78 | but the undersigned counsel for Chase inadvertently (and, apparently, incorrectly) believed th the briefing would be sequential (with Chase’s response brief to be filed on January 10, 202: and Plaintiff's reply (if any) to be filed on January 24, 2022).

12 4, The undersigned Counsel have discussed this situation, and respectfully ask th 13 |) Court to extend/modify the briefing deadlines and protocol arising from the November 19, 202 2 Z 14 |! status hearing as follows: z g : = . (i) Chase’s initial brief (and its opposition to Plaintiff's December 20, 2021 bric (Docket No. 78)) shall be due on Monday, January 10, 2022; = < 18 (11) Plaintiff's opposition to Chase’s initial brief (and its reply, if any, relative | 19 Plaintiff's December 20, 2021 brief) shall be due on Monday, January 31, 202: 20 and, (iii) any reply of Chase (if any) shall be due no later than Monday, February 1: 33 2022. a4 {}\\\ |1\\\ N\\\ \\\ 1 5. The parties respectfully submit that the instant stipulation (and the extension s ? |! forth herein) is not requested for purposes of delay, but is submitted in good faith to address a inadvertent error in this matter and to allow the parties to orderly brief the issues before tt Court.

6 || Dated this 3°¢ day of January, 2022. Dated this 3% day of January, 2022.

7 || SMITH LARSEN & WIXOM LAW OFFICES OF MICHAEL F. BOHN 3 ESQ., LTD. || /s_Kent F. Larsen /s/ Michael F. Bohn Kent F. Larsen, Esq. Michael F. Bohn, Esq.

10 || Nevada Bar No. 3463 Nevada Bar No. 1641 1935 Village Center Circle 2260 Corporate Cir., Suite 480 Las Vegas, Nevada 89134 Henderson, Nevada 89074 || Attorneys for Defendant/Counterclaimant Attomey for Plaintiff/Counterdefendant JPMorgan Chase Bank, N.A. Shirehampton Drive Trust °

IT IS SO ORDERED: n > nag BS5E 18 .

19 UNITER STA AGISTRATE 20 JUDGE DATED: January 3, 2022.