United States District Court, D. Nevada
LEONARD C. ADAMS, et al, Plaintiffs,
COMPASS PARTNERS, LLC, et al, Defendants.
T. Hayward LAXALT & NOMURA, LTD. Attorneys for the
Michael J. Collins, Robert M. Millimet Brewer Attorneys &
Counselors Attorneys for Plaintiffs
Rasmussen Law Office of Lisa Rasmussen Attorneys for
Plaintiffs (except Daniel Newman)
Clark Lipson, Neilson, Cole, Seltzer & Garin, P.C.
Attorneys for Plaintiff Daniel Newman
L. Olson, in pro per
STIPULATION / JOINT MOTION TO EXTEND DISPOSITIVE
MOTION AND PROPOSED JOINT PRETRIAL ORDER DUE DATES PENDING
COMPLETION OF PROPOSED SETTLEMENT (FOURTH REQUEST) AND
REQUEST FOR STATUS CONFERENCE
C. Jones, Senior District Judge.
Plaintiff Direct Lenders, by and through their attorneys
Michael J. Collins and Robert M. Millimet of Brewer,
Attorneys and Counselors and Lisa Rasmussen of the Law Office
of Lisa Rasmussen, Plaintiff Direct Lender Daniel Newman, by
and through his attorneys Michael J. Collins and Robert M.
Millimet of Brewer, Attorneys and Counselors and David Clark
of Lipson, Neilson, Cole, Seltzer & Garin, P.C.,
Defendants David Blatt, Jay Cohen, Leonard Mezei, Ron
Friedman, Compass Financial Partners, LLC, Compass FP Corp.,
Compass Partners, LLC, Compass USA GP, LLC, Compass USA
Holding, LLC, Compass USA, LP, Compass USA SPE, LLC, Economic
Growth Group, Inc., and Repotex, Inc. (collectively, the
"Compass Defendants"), by and through their
attorneys Daniel T. Hayward and Holly S. Parker of Laxalt
& Nomura, Ltd., and Defendant Mark L. Olson, in pro per,
hereby stipulate and jointly move the Court pursuant to LRIA
6-1, LR II26-4, and FRCP 16(b)(4) for an Order extending the
existing June 2, 2018 dispositive motion deadline and the
existing July 31, 2018 proposed Joint Pretrial Order due
Plaintiff Direct Lenders and Compass Defendants'
representatives have signed a proposed Settlement Agreement,
and the Plaintiff Direct Lenders will soon be filing a Motion
for Approval of Settlement. However, there is
insufficient time between now and the June 2, 2018
dispositive motion due date for the forthcoming Motion for
Approval of Settlement to be fully briefed (in the event any
opposition is filed) and decided by the Court. And, the parties
believe that the filing of a motion for summary judgment in
the interim would likely be damaging to the cause of
settlement. Further, if the proposed settlement is approved
but one or more claims by non-settling Plaintiff Direct
Lenders remain, the parties would be able to draft far more
streamlined dispositive motions and a Joint Pretrial Order
after it has been determined which specific loans -
if any - remain at issue.
Plaintiff Direct Lenders are confirming their settlement vote
totals and assessing how best to achieve Court approval of
the settlement. Thus, the parties respectfully request that
the Court set a status conference in approximately 60 days to
discuss this case, including the Court's approval of the
forthcoming Motion for Approval of Settlement.
the parties' fourth request for a continuance of these
pretrial due dates and the related requested relief. It is
the parties' first request for a status conference
regarding these issues.
case was originally filed on March 6, 2011, by the Plaintiff
Direct Lenders against the Compass Defendants and numerous
other Defendants. Following various motions to dismiss,
pleading amendments, and settlements, Plaintiffs filed a
Second Amended Complaint on November 1, 2012 against the
Compass Defendants, Oakbridge Capital Inc., Mark Olson,
Windemere Capital, LLC, Tyson Lomazow, and the Citron
Defendants. (ECF No. 176.)
Compass Defendants filed an Answer and Affirmative Defenses
to Second Amended Complaint in ...