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Agha-Khan v. Wells Fargo Bank NA

United States District Court, D. Nevada

May 30, 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 FINANICAL CORPORATION, a financial concern, form unknown; MARTIN CONVEYANCING CORP AKA MARTIN 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; BRETT P. RYAN, an individual and attorney at Routh Crab tree Olsen, PS; JOHNATHAN J. DAMEN, an individual and attorney at Routh Crab tree Olsen, PS; JEFF ROMIG 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 SANBERG, a Wells Fargo employee; AND DOES 1 THROUGH 1000 INCLUSIVE, Defendants.

          Zachary T. Ball, Esq. THE BALL LAW GROUP Attorney for Navy Federal Credit Union, Jeffrey L. Romig and Patricia Romig (formally known as Patricia Krause)

          MOTION TO EXTEND TIME TO RESPOND TO COUNTERCLAIM

         Pursuant to Federal Rule of Civil Procedure 6(b), Defendant-Intervenor NAVY FEDERAL CREDIT UNION ("Navy Federal"), by and through its attorney, Zachary T. Ball, Esq. of Ball Law Group, hereby requests an Order granting additional time, up to June 1, 2017 (10 days from the date of this Motion) to file a responsive pleading to Plaintiff/Counterclaimant SALMA AGHA-KHAN, M.D.'S ("Plaintiff/Counterclaimant") Counterclaim to NAVY FEDERAL'S Complaint in Intervention [Document #82].

         POINTS AND AUTHORITIES

         Plaintiff/Counterclaimant's initial Complaint was filed on December 16, 2016, by filing his in proper person Complaint [Document #1] which spans 75 pages, asserts 16 causes of action, and includes 236 separate factual allegations that require individual responses.

         Navy Federal, the moving party, filed a Complaint in Intervention to which Plaintiff/ Counterclaimant answered and filed a Counterclaim against Nevada Federal on or about May 1, 2017 [Document #82]. This document contains an Answer to Navy Federal's Complaint in Intervention as well as a Counterclaim, the latter of which is 23 pages long (not including exhibits, the Answer, and the declaration of Plaintiff/Counterclaim, which bring the total length of the pleading to 68 pages). It multiple causes of action and contains 93 paragraphs which require individual responses.

         It is this pleading (i.e. Plaintiff/Counterclaimant's Counterclaim against Nevada Federal [Document #82]) which is at issue in this Motion. A responsive pleading to said Counterclaim is due on the date of this filing (May 22, 2017). By way of this Motion, Navy Federal seeks a brief 10-day extension (which, by Navy Federal's calculation, is June 1, 2017) to file said responsive pleading. This request is made pursuant to F.R.C.P. 6(b)(1)(A) as Navy Federal's time period to respond to the Counterclaim has not yet passed.

         Good cause exists to extend the time to respond to the Counterclaim because the length of the 68-page pleading (including exhibits), the complexity presented in the causes of action and the 93 paragraphs of factual allegations and prayers for relief, and the investigation and research that will be necessary to respond to all. The requested time is needed to investigate the facts and analyze the applicable law in order to prepare an appropriate response.

         Moreover, it is unlikely Plaintiff/Counterclaimant will be prejudiced in any way by the minimal amount of time (10 days) Navy Federal is requesting to respond. This is a very short amount of time and will not impact the matter in any way.

         CONCLUSION

         For these reasons, Navy Federal respectfully requests an extension of time to respond to ...


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