Resorts World Las Vegas LLC v. Keybank National Association

District Court, D. Nevada

Resorts World Las Vegas LLC v. Keybank National Association

Trial Court Opinion

1 Kelly H. Dove Nevada Bar No. 10569 2 Jesse Hogin Nevada Bar No. 14884 3 SNELL & WILMER L.L.P. 1700 South Pavilion Center Drive, Suite 700 4 Las Vegas, Nevada 89135 Telephone: (702) 784-5200 5 Facsimile: (702) 784-5252 [email protected] 6 [email protected]

7 Attorneys for Defendant KeyBank National Association 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 11 RESORTS WORLD LAS VEGAS LLC dba Case No. 2:25-cv-00307-GMN-BNW 12 RESORTS WORLD LAS VEGAS,

13 Plaintiff, STIPULATION AND ORDER TO EXTEND DEADLINES 14 v. (FIRST REQUEST) 15 JIA TANG; JING GONG; AI KONG;

16 KEYBANK NATIONAL ASSOCIATION; FIRST TECHNOLOGY FEDERAL CREDIT UNION dba FIRST TECH FEDERAL 17 CREDIT UNION; DOES 1 through 10, inclusive; and ROE CORPORATIONS 1 18 through 10, inclusive, 19 Defendants.

20 21 Plaintiff, Resorts World Las Vegas LLC dba Resorts World Las Vegas “Resorts World;” 22 Defendant KeyBank National Association (“KeyBank”); Defendant Jing Gong; and Defendant Ai 23 Kong, (collectively “the Parties”); by and through their respective undersigned counsel, hereby 24 stipulate to extend all applicable deadlines by 60 days with the following background and reasons: 25 1. Defendant KeyBank removed this action to this Court on February 14, 2025. 26 2. KeyBank’s deadline to respond to the Complaint is currently February 21, 2025. 27 3. Defendant Ai Kong’s deadline to respond to the Complaint is currently February 21, 28 2025. 1 4. Defendant Jing Gong filed an Answer on February 11, 2025, prior to removal. 2 5. Defendant First Tech filed an Answer on February 13, 2025, prior to removal. 3 6. Pursuant to this Court’s Minute Order of February 20, 2025 (ECF No. 4), the 4 Discovery Plan and Scheduling Order is currently due by March 31, 2025. 5 7. Under Federal Rule of Civil Procedure 26(f), a conference must be held by March 6 10, 2025. 7 8. The Parties are currently and substantively engaged in attempts at an early resolution 8 and as such request that each of the applicable deadlines be extended for sixty (60) days so they 9 may pursue those efforts. 10 9. As such, the Parties agree that KeyBank’s and Ai Kong’s deadline to respond to the 11 Complaint will be April 22, 2025; that the deadline to hold a 26(f) conference will be May 9, 2025; 12 and the deadline to file a Discovery Plan and Scheduling Order will be May 30, 2025. 13 10. The Parties agree that this stipulation is entered into in good faith and not for the 14 purpose of delay. 15 IT IS SO STIPULATED. 16 Dated: February 21, 2025. Dated: February 21, 2025.

17 SNELL & WILMER L.L.P. AI KONG 18 By: /s/ Kelly H. Dove By: /s/ Ai Kong 19 Kelly H. Dove (NV Bar No. 10569) Ai Kong Jesse Hogin (NV Bar No. 14884) 465 147th Place NW 20 1700 S. Pavilion Center Dr., Ste 700 Bellevue, WA 98007 21 Las Vegas, Nevada 89135 Pro Se Attorneys for Defendant KeyBank 22 National Association

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24 25 26 27 28 Dated: February 21, 2025. Dated: February 21, 2025. 2 || JING GONG SKLAR WILLIAMS PLLC 3 By: /s/ Jing Gong By: /s/ Anthony R. Ager 4 Jing Gong Anthony R. Ager (NV Bar No. 7969)

14907 SE 64

" St. 410 South Rampart Blvd., Suite 350 5 Bellevue, WA 98006 Las Vegas, NV 89145 6 Pro Se Attorneys for Plaintiff Resorts World Las Vegas LLC 7 8 9 IT IS SO ORDERED. 10 les 11 ITED STATES DISTRICT JUDGE OR UNITED STATES MAGISTRATE JUDGE 12 DATED: 2/25/2025

| 4 Respectfully submitted by: 15 || SNELL & WILMER LLP.

| 21 16 || By: Kelly H. Dove a Kelly H. Dove, Esq. (NV Bar No. 10569) 17 Jesse Hogin (NV Bar No. 14884) 1700 S. Pavilion Center Dr., Ste 700 18 Las Vegas, Nevada 89135 19 Attorneys for Defendant Wells Fargo Bank, N.A. 20 21 22 23 24 25 26 27 28 _3-

1 CERTIFICATE OF SERVICE 2 I hereby certify that on February 21, 2025, I served the foregoing STIPULATION AND 3 ORDER TO EXTEND DEADLINES by the methods indicated below. 4  BY FAX: by transmitting via facsimile the document(s) listed above to the fax number(s) set forth below on this date before 5:00 p.m. pursuant to EDCR Rule 5 7.26(a). A printed transmission record is attached to the file copy of this document(s). BY U.S. MAIL: by placing the document(s) listed above in a sealed envelope with 6  postage thereon fully prepaid, in the United States mail at Las Vegas, Nevada addressed as set forth below: 7 8  BY OVERNIGHT MAIL: by causing document(s) to be picked up by an overnight delivery service company for delivery to the addressee(s) on the next business day. 9  BY EMAIL: by emailing a PDF of the document listed above to the email addresses 10 of the individual(s) listed below.

11 AI KONG [email protected] 12 JING GONG 13 [email protected]

14  BY PERSONAL DELIVERY: by causing personal delivery by, a messenger service 15 with which this firm maintains an account, of the document(s) listed above to the person(s) at the address(es) set forth below. 16  BY ELECTRONIC SUBMISSION: submitted to the above-entitled Court for 17 service upon the Plaintiff and First Tech in the above-referenced case.

18 DATED: February 21, 2025 /s/ Kelly H. Dove An employee of Snell & Wilmer L.L.P. 19

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21 4936-9908-7390

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Reference

Status
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