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Agha-Khan v. Wells Fargo Bank, NA

United States District Court, D. Nevada

February 2, 2017

SALMA AGHA-KHAN, MD, an individual, Plaintiff,
v.
WELLS FARGO BANK, NA, A U.S. Bank; WELLS FARGO FINANCIAL NATIONAL BANK, A National Banking Association; WELLS FARGO HOME MORTGAGE, a Wells Fargo Bank, NA subsidiary; MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC, a Delaware agency/corporation, form unknown; MERSCORP HOLDINGS INC., holding/parent company of MERS Inc.; TBI MORTGAGE COMPANY, a mortgage company; GMAC MORTGAGE, LLC FKA GMAC MORTGAGE CORPORATION, a financial lending business; OCWEN FINANCIAL CORPORATION, a financial concern, form unknown; MARIN CONVEYANCING CORP AKA MARIN CONVEYANCING CORPORATION, a lending corporation form unknown; EXECUTIVE TRUSTEE SERVICES, LLC, a defunct Delaware company form unknown; FIRST AMERICAN TITLE COMPANY, a title agency form unknown; FIRST AMERICAN TITLE INSURANCE COMPANY, a title insurance company form unknown; ROUTH CRABTREE OLSEN PS. a law firm in California; EDWARD T. WEBER, an individual and attorney at Routh Crabtree Olsen PS; BRET P. RYAN, an individual and attorney at Rough Crabtree Olsen PS; JOHNATHAN J. DAMEN, an Individual and attorney at Routh Crabtree Olden PS; JEFF ROMIS AKA JEFFREY L. ROMIG, an individual; PATRICIA J. KRAUSE, an individual; GREENPOINT MORTGAGE FUNDING, INC., a mortgage company form unknown; SERVICELINK AKA SERVICELINK, LLC a business organization form unknown; LSI TITLE AGENCY INC., a title agency form unknown; CHICAGO TITLE COMPANY, a title company form unknown; FIDELITY NATIONAL DEFAULT SOLUTIONS, INC., a company form unknown; NATIONWIDE TITLE CLEARING, a title company form unknown; AMANDA ROSE JONES, an individual and Assistant Secretary for MERS Inc., KRISTOPHER JAMES SANDBERG, a Wells Fargo employee; and DOES 1 THROUGH 1000, INCLUSIVE, Defendants.

          WRIGHT, FINLAY & ZAK, LLP Dana Jonathon Nitz, Esq. Nevada Bar No. 0050 Natalie C. Lehman, Esq. Nevada Bar No. 12995 YanXiong Li, Esq. Nevada Bar No. 12807 Attorneys for OCWEN FINANCIAL CORP., MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., MERSCORP HOLDINGS INC.

          MOTION TO EXTEND TIME TO RESPOND TO COMPLAINT

          Peggy A. Leen United States Magistrate Judge

         Pursuant to Federal Rule of Civil Procedure 6(b), Defendants, OCWEN FINANCIAL CORP., MORTGAGE ELECTRONIC REGISTRATION SYSTEMS, INC., MERSCORP HOLDINGS INC. hereby request an order granting additional time, up to and including March 1, 2017, to file a responsive pleading to Plaintiffs pro per 75 page, 236 paragraph Complaint. This is the first request for an extension of this deadline. This Motion is based upon the attached points and authorities, the pleadings and papers on file herein and any argument of counsel that may be considered at the hearing on this Motion by the Court.

         POINTS AND AUTHORITIES

         Plaintiff commenced this lawsuit on December 16, 2016, by filing his pro per Complaint (ECF No. 1). The Complaint spans 75 pages, asserts 16 causes of action, and includes 236 separate factual allegations that require individual response. The Complaint identifies as defendants: Ocwen Financial Corp. ("Ocwen"), Mortgage Electronic Registration Systems, Inc. ("MERS"), MERSCorp Holdings Inc. ("Merscorp"), among the 26 separate individual and entity defendants named.

         Defendant Ocwen was served with the Complaint on January 11, 2017, making its deadline to respond to the Complaint February 1, 2017. It is currently unclear when or even if all the other defendants have been served. Defendant Ocwen first retained counsel on January 24, 2017 and will defend on behalf of all named defendants pursuant to its pre-existing agreements with the various defendants. By this Motion, all named Defendants jointly request an extension of time to respond up to and including March 1, 2017. This request is being made pursuant to F.R.C.P. 6(b)(1)(A) as the time period to respond to the Complaint has not yet passed for any of the Defendants.

         Good cause exists to extend the time to respond to the pro per Complaint because of the length of the 75 page pleading, the complexity presented in its 16 causes of action, and the investigation and research necessary to respond to the separate 236 paragraphs of allegations. The requested time is needed to investigate the facts and analyze the applicable law in order to prepare a response. Moreover, multiple defendants will need to review and approve the response before it can be filed. Defendants submit that the additional time requested is reasonable, particularly in light of the above listed factors.

         CONCLUSION

         For these reasons, Defendants respectfully request an extension of the time to respond to ...


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