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

Opinion

1 || Kent F. Larsen, Esq. 5 Nevada Bar No. 3463 SMITH LARSEN & WIXOM 3 || 1935 Village Center Circle Las Vegas, Nevada 89134 4 |! Tel.: (702) 252-5002 5 Fax: (702) 252-5006 Email: kfl@slwlaw.com 6 || Attorneys for Defendant/Counterclaimant JPMorgan Chase Bank, N.A. 10 || SHIREHAMPTON DRIVE TRUST, CASE NO.: 2:16-cv-02276-RFB-EJY Plaintiff, 12 V. a = 4 JPMORGAN CHASE BANK, NATIONAL | STIPULATION AND ORDER TO 2 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) 18 JPMORGAN CHASE BANK, N.A., 19

50 Counterclaimant, 21 Vv. 22 || SHIREHAMPTON DRIVE TRUST; DOES 33 1 through 10, inclusive; and ROE CORPORATIONS 1 through 10, inclusive, 24 Counterdefendants. 25 26 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 2 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 6 || 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 8 | 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 28 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, 21 (iii) any reply of Chase (if any) shall be due no later than Monday, February 1:

33 2022. a4 {}\\\ 25 |1\\\ 76 N\\\ 27 \\\ 28

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 9 || /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 12 || Attorneys for Defendant/Counterclaimant Attomey for Plaintiff/Counterdefendant JPMorgan Chase Bank, N.A. Shirehampton Drive Trust

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16 IT IS SO ORDERED: 17 n > nag BS5E 18 .

20 JUDGE DATED: January 3, 2022. 21 22 23 24 25 26 27 28