Grogan v. Allied Solutions, LLC

1 Marquis Aurbach Christian T. Balducci, Esq.

2 Nevada Bar No. 12688 Tabetha Steinberg, Esq.

3 Nevada Bar No. 16756 10001 Park Run Drive Las Vegas, Nevada 89145 Telephone: (702) 382-0711 Facsimile: (702) 382-5816 [email protected] [email protected] Attorneys for Defendants Allied Solutions, LLC, Ohio Indemnity Company, and Secure Collateral Management UNITED STATES DISTRICT COURT DISTRICT OF NEVADA SANDRA GROGAN, CASE NO.: 2:24-CV-01669-APG-MDC Plaintiff, STIPULATION AND ORDER TO V. EXTEND DEFENDANTS ALLIED SOLUTIONS, LLC, OHIO ALLIED SOLUTIONS, LLC; OHIO INDEMNITY COMPANY, SECURE INDEMNITY COMPANY; SECURE COLLATERAL MANAGEMENT, COLLATERAL MANAGEMENT; AND RECOVERY NETWORK OF INTOUCH CREDIT UNION; AND NEVADA, INC., TIME TO FILE A RECOVERY NETWORK OF NEVADA, RESPONSIVE PLEADING TO INC. PLAINTIFF’S COMPLAINT (ECF NO. 1) 18 Defendants. (FIRST REQUEST)

Plaintiff Sandra Grogan (“Plaintiff”), by and through her counsel of record, George Haines, Esq., and Gerardo Avalos, Esq., of the law firm Freedom Law Firm, LLC, Defendants Allied Solutions, LLC (“Allied”), Ohio Indemnity Company (“Ohio”), and Secure Collateral Management (“Secure”), by and through their counsel of record, Tabetha J. Steinberg, Esq. and Christian T. Balducci, Esq., of the law firm of Marquis Aurbach, and Defendant Recovery Network of Nevada, Inc. (“Recovery”), by and through its counsel of record, Jeff Sloane, Esq., of Sloane/Tygret Law Group, hereby jointly agree and stipulate as follows: 3 1. Plaintiff filed her Complaint on September 10, 2024 (ECF No. 1); 4 2. Allied, Ohio, Secure, and Recovery’s current deadline to respond to Plaintiff’s 5 Complaint is October 11, 2024; 6 3. Allied, Ohio, Secure, and Recovery are unable to meet the October 11, 2024, 7 deadline to file a responsive pleading to Plaintiff’s Complaint; 8 4. The parties are also discussing potential settlement and resolution of Plaintiff’s 9 claims as alleged in her Complaint; 10 5. Plaintiff does not oppose granting Allied, Ohio, Secure, and Recovery an 11 extension to file a responsive pleading to the Complaint; 12 6. Pursuant to LR IA 6-1, Allied, Ohio, Secure, and Recovery request for this Court 13 to grant an extension of time to file a responsive pleading for thirty (30) days; 14 7. The new deadline for Allied, Ohio, Secure, and Recovery to file a responsive 15 pleading to Plaintiff’s Complaint is stipulated and agreed to be November 9, 16 2024; 17 8. This is Allied, Ohio, Secured, and Recovery’s first request to extend the deadline 18 to file a responsive pleading to Plaintiff’s Complaint; and 19 9. This Stipulation is being made in good faith and not for purposes of delay.

20 / / / / / / / / / / / / / / / / / / / / / / / / 1 IT IS SO STIPULATED.

2 || Dated this 11" day of October, 2024 Dated this 11" day of October, 2024 MARQUIS AURBACH FREEDOM LAW FIRM, LLC || By:4s/ Christian T. Balducci By:/s/_ Gerardo Avalos Christian T. Balducci, Esq. George Haines, Esq.

6 Nevada Bar No. 12688 Nevada Bar No. 9411 Tabetha Steinberg, Esq. Gerardo Avalos, Esq.

7 Nevada Bar No. 16756 Nevada Bar No. 15171 10001 Park Run Drive 8985 South Eastern Avenue 8 Las Vegas, Nevada 89145 Las Vegas, Nevada 89123 9 Attorneys for Defendants Allied Attorneys for Plaintiff Solutions, LLC, Ohio Indemnity 10 Company, and Secure Collateral Management Dated this 11 day of October, 2024 SLOANE/TYGRET LAW GROUP 15 || By: 4/ Jeffrey G. Sloane Jeffrey G. Sloane, Esq. = 16 Nevada Bar No. 784 510 South 8" Street 17 Las Vegas, Nevada 89101 ~ Attorneys for Defendant Recovery Network of 18 Nevada, Inc. 19 ORDER 21 The above Stipulation is hereby GRANTED.

22 IT IS SO ORDERED: LZ. Zp □□□ 23 4b & 24 fv \ 5 Hon.laximiliand/D. Cguvillier II United States Magistrage Judge 26 DATED: 10/15/2024 Page 3 of 3