ROGER P. CROTEAU, ESQ.
Nevada Bar No. 4958
TIMOTHY E. RHODA, ESQ.
Nevada Bar No. 7878
ROGER P. CROTEAU & ASSOCIATES, LTD.
Attorney for Defendant
AKERMAN, LLP
SCOTT R. LACHMAN, ESQ.
Nevada Bar No. 12016
DONNA M. WITTIG, ESQ.
Nevada Bar No. 11015
Attorney for Plaintiff U.S. Bank National Association
THUNDER PROPERTIES, INC. ORDER TO EXTEND TIME TO RESPOND TO MOTION FOR SUMMARY JUDGMENT AND MOTION TO STAY DISCOVERY
COMES NOW, Defendant, THUNDER PROPERTIES, INC., and Plaintiff, U.S. BANK NATIONAL ASSOCIATION, AS TRUSTEE FOR THE SPECIALTY UNDERWRITING AND RESIDENTIAL FINANCE TRUST AND MORTGAGE LOAN ASSET-BACKED CERTIFICATES SERIES 2006-BC4, by and through their undersigned counsel, and hereby stipulate and agree as follows:
1. On March 26, 2024, Plaintiff caused a Motion for Summary Judgment and Motion for Protective Order or Motion to Stay Discovery to be filed herein. [ECF #91, 92, 93]. Responses to said Motions are presently due on or about April 9, 2024 and April 16, 2024.
2. Defendant's counsel is unable to prepare and file responses by the current deadlines due to various other personal and professional obligations, including the preparation and filing of a Motion to Compel Discovery which is associated with this dispute. Moreover, it will be more efficient and economical to prepare and file all of the required pleadings together.
3. Defendant has requested and shall be granted an extension of time to respond to Plaintiff's Motion for Summary Judgment and Motion for Protective Order or Motion to Stay Discovery until April 30, 2024.
4. This Stipulation is made in good faith and not for purpose of delay.
IT IS SO ORDERED.