1 || JOSEPH Y. HONG, ESQ. Nevada Bar No. 5995 2 || HONG & HONG LAW OFFICE 1980 Festival Plaza Dr., Suite 650 3 || Las Vegas, Nevada 89135 Telephone: (702) 870-1777 4 || Facsimile: (702) 870-0500 5 Email: [email protected] 6 Attorney for Danny, LLC 7 UNITED STATES DISTRICT COURT 8 DISTRICT OF NEVADA 9 10 |] DANNY, LLC, a Nevada limited liability Case No.: 2:22-cv-00294-APG-VCF company, 11 12 Plaintiff, STIPULATION AND ORDER FOR 13 || vs. REMAND TO STATE COURT 14 || QUALITY LOAN SERVICE CORPORATION, 15 ||? California corporation registered with the Nevada Secretary of State; NEWREZ LLC dba 16 {| SHELLPOINT MORTGAGE SERVICING, a Delaware limited liability company registered 17 || with the Nevada Secretary of State; NEVADA LEGAL NEWS, LLC, a Nevada limited liability 18 || company; DOES I through X and ROE 19 BUSINESS ENTITIES I through X, inclusive, 20 Defendants. 21 22 23 24 Defendant, NewRez LLC dba Shellpoint Mortgage Servicing (Shellpoint) and Plaintiff, Danny, 25 LLC (Danny), by and through their attorneys of record, file this stipulation to remand this case to 2% State Court. In support of this stipulation, the parties state as follows: 7 1. On February 16, 2022, Defendant, Shellpoint, filed its Petition for Removal of this case 28 from the Eighth Judicial District Court, case number A-22-847704-C [ECF NO.1].

1 2. Defendant, Shellpoint’s, Petition for Removal was based on diversity jurisdiction under 2 ||

. Diversity jurisdiction “requires ‘complete diversity’ of citizenship, meaning that 3 || the ‘citizenship of each plaintiff is diverse from the citizenship of each defendant.’” Demarest v. 4 || HSBC Bank USA, N.A., 920 F, 3d 1233, 1226 (9" Cir. 2019) (quoting Caterpillar Inc. v. Lewis, 509 5 || U.S. 61, 68 (1996)). 6 3. Plaintiff, Danny, is a Nevada limited liability company and, therefore, is “a citizen of 7 || every state of which its owners/members are citizens.” Johnson v. Columbia Props. Anchorage, LP, 8 ||

(9" Cir. 2006). Since the establishment and organization of Plaintiff, Danny, in 9 || 2019, the owners/members of Plaintiff, Danny, are and continue to be Portfolio Management LLC, a 10 || California limited liability company and Farhad Yazdinian, a natural person. Farhad Yazdinian has 11 |; been, and continues to permanently reside and be permanently domiciled in the State of California as 12 || he has his true, fixed, and permanent home and principal establishment in the State of California and 13 || he intends to return to the State of California whenever he is absent from it. Farhad Yazdinian, 14 |} therefore, is a citizen of the State of California. 15 4. Defendant, Quality Loan Servicing Corporation, is a California corporation wherein a 16 || corporation is a citizen of both its state of incorporation and the state where it has its principal place of 17 || business. Hertz Corp. v, Friend,

(2010) (quoting

□ □□ (1). 18 || Defendant, Quality Loan Servicing Corporation, therefore, is a citizen of the State of California. 19 |]... 20 || ... 21 ||... 22 Il... 23 || ... 24 ||... 25 || ... 26 || ... 27 || ... 28 ...

1 5. Based on the following, the parties submit that diversity jurisdiction for this case does 2 || not exist and, therefore, request and stipulate for remand of this case to State Court. 3 4 DATED: February 28, 2022. 5 AKERMAN LLP Honc & Hone Law OFFICE 6 || 4/Natalie L. Winslow Joseph ¥. Hong □□ ARIEL E. STERN, ESQ. JOSEPH Y. HONG, ESQ. 7 || Nevada Bar No. 8276 Nevada Bar No. 5995 _ NATALIE L. WINSLOW, ESQ. 1980 Festival Plaza Drive, Suite 650 g || Nevada Bar No, 12125 Las Vegas, NV 89135 PAIGE L. MAGASTER, ESQ. g || Nevada Bar No. 15557 Attorney for Danny, LLC 1635 Village Center Circle, Suite 200 10 || Las Vegas, NV 89134 «|| Attorneys for NewRez LLC dba Shellpoint Mortgage Servicing 12 IT IS SO ORDERED. 14 15 (fe UNITED STATES DISTRICT JUDGE -16 Case No.: 2:22-cv-00294-APG-VCF 17 DATED: March 1, 2022 18 19 20 21 22 23 24 25 26 27 28 .