United States District Court, D. Nevada
DEFENDANTS REQUEST FOR ADDITONAL TIME TO
WEKSLER UNITED STATES MAGISTRATE JUDGE
Jonathan Hanley (“Hanley”), in respectfully
asking that this court grant him 7 additional days to respond
to Plaintiff FTC's Motion to Determine Sufficiency of
Answers states as follows:
nature and importance of this motion have required a
substantial amount of time to craft a proper response. Hanley
has prepared a response in connection with the portion of the
motion that corresponds to the FTC Firsts Request for
Admission of Fact. The response is written but requires
further perfection concerning exhibits and a Declaration. The
draft response is attached. (Hanley Decl. Att. A.)
research has been commenced for crafting a proper response to
the part of the motion at bar concerning the FTC's second
request for admission of fact, but a version that is suitable
for filing is not even close to being ready.
the first request for an extension of time to file a pleading
that Hanley has made during the pendency of this litigation.
Hanley sent counsel for FTC an e-mail requesting additional
time, but it was sent very late in the evening.
breadth of motion practice that is occurring at this point in
the litigation is substantial and time consuming. Hanley is
pro se and while he should be held to the same
standards as opposing counsel the logistics of effectively
handling this litigation with the Motion Practice at hand is
I ask this Court grant 7 additional days, or until May
22n to reply to The FTC's Motion to Determine
Sufficiency of Answers.
IS SO ORDERED
OPPOSITION TO PLAINTIFFS MOTION TO DETERMINE THE SUFFICIENCY
OF ANSWERS TO REQUEST FOR ADMISSION
Jonathan Hanley (“Hanley”) opposes Plaintiff
Federal Trade Commission's (FTC) Motion to Determine the
Sufficiency of Answers to Requests for Admission and
respectfully requests that this Court deny the motion. A
proposed order is attached. In opposition of the Motion
Hanley states as follows:
files this motion in connection with Hanley's timely
responses to 556 Request for Admission of Fact. In their
background statement (ECF. No. 208 at 2:13- 17) the
FTC represents to this Court that their second request for
admission was served on December 26th 2018 and
then ultimately responded to on February 27th
2018. The FTC misrepresents this fact to the Court as the
actual response was served in a timely manner on January
24th 2019. (Hanley Decl. ¶ 3.)
further misrepresents the facts of the case at this point.
Their complaint certainly makes very serious allegations
against the defendants. These allegations are misguided and
wrong. The FTC has already responded to hundreds of Hanley
requests for admission wherein consumer received modified
mortgages with features such as 0% to 3% interest rates,
millions of dollars of forgiven principal, tens of millions
of dollars of deferred principal and mortgage payments
wherein the savings to consumers typically ranged from 20% to
40% savings. This litigation is abusive and a perversion of
the unchecked powers that are at the FTC's disposal. It
is important to note that the FTC is now vehemently
attempting to avoid responding to additional meritorious
requests for admission that have been propounded by Hanley.
Their evasive tactics have been raised in a pending Motion
for Extension of Discovery that has been filed by Hanley.
(ECF No. 216.)
MEET AND CONFER EFFORTS ...