United States District Court, D. Nevada
DIAMOND RESORTS INTERNATIONAL, INC., a Delaware Corporation; DIAMOND RESORTS CORPORATION, a Maryland Corporation; DIAMOND RESORTS U.S. COLLECTION DEVELOPMENT, LLC, a Delaware Limited Liability Company; and DIAMOND RESORTS MANAGEMENT, INC., an Arizona Corporation, Plaintiffs,
REED HEIN & ASSOCIATES, LLC d/b/a TIMESHARE EXIT TEAM, a Washington Limited Liability Company; BRANDON REED, an individual and citizen of the State of Washington; TREVOR HEIN, an individual and citizen of Canada; THOMAS PARENTEAU, an individual and citizen of the State of Washington; HAPPY HOUR MEDIA GROUP, LLC, a Washington Limited Liability Company; MITCHELL R. SUSSMAN, ESQ. d/b/a THE LAW OFFICES OF MITCHELL REED SUSSMAN & ASSOCIATES, an individual and citizen of the State of California; SCHROETER, GOLDMARK & BENDER, P.S., a Washington Professional Services Corporation; and KEN B. PRIVETT, ESQ., a citizen of the State of Oklahoma, Defendants.
Richard W. Epstein, Esq., Jeffrey Backman, Esq., Michelle
Durieux, Esq., GREENSPOON MARDER LLP, Phillip A. Silvestri,
Esq., GREENSPOON MARDER LLP, Gregory Kraemer COOPER LEVENSON,
P.A., Attorneys for Plaintiffs.
REES SCULLY MANSUKHANI, LLP, ROBERT S. LARSEN, ESQ., DAVID T.
GLUTH, II, ESQ., DIONE C. WRENN, ESQ., Attorneys for
Defendants Reed Hein & Associates, LLC dba Timeshare Exit
Team, Brandon Reed, Trevor Hein, Thomas Parenteau, and Happy
Hour Media Group, LLC.
NEILSON, P.C., JOSEPH P. GARIN, ESQ., MEGAN H. HUMMEL, ESQ.,
Attorneys for Defendant Schroeter, Goldmark & Bender,
ALVERSON TAYLOR & SANDERS, LEANN SANDERS, ESQ., COURTNEY
CHRISTOPHER, ESQ., Attorney for Defendant Ken B. Privett,
JOINT STIPULATION TO EXTEND DEADLINES [SECOND
to Local Rules 6-1 and 7-1, Plaintiff DIAMOND RESORTS
CORPORATION (“DRC”), and Defendants REED HEIN
& ASSOCIATES, LLC d/b/a TIMESHARE EXIT TEAM, BRANDON
REED, TREVOR HEIN, THOMAS PARENTEAU (collectively, “TET
Defendants”), HAPPY HOUR MEDIA GROUP, LLC
(“HHMG”), MITCHELL REED SUSSMAN, ESQ. d/b/a THE
LAW OFFICES OF MITCHELL REED SUSSMAN & ASSOCIATES
(“Sussman”), SCHROETER GOLDMARK & BENDER,
P.S. (“SGB”), and KEN B.. PRIVETT, ESQ.
(“Privett”), by and through their respective
attorneys of record, stipulate as stated below. TET
Defendants, HHMG, Sussman, SGB, and Privett are collectively
referred to as “Defendants”. DRC and Defendants
are collectively referred to herein as the
“Parties”. The Parties hereby stipulate and agree
1. On November 25, 2019, this Court granted in part TET
Defendants and HHMG's Motions to Dismiss (hereinafter,
the “Order”) [ECF No. 141].
2. The Order provided Plaintiff until December 23, 2019 to
file a Second Amended Complaint (“SAC”).
3. Due to the upcoming holiday season, the Parties stipulated
to extend the deadline to file the SAC until January 12, 2020
(ECF #142). The Court granted the requested extension on
December 20, 2019 (ECF No. 144).
4. In the SAC, Plaintiff intends to significantly narrow the
scope of this litigation, most notably by drastically
reducing the number of timeshare owners that are the subject
of this litigation.
5. Since the prior extension was granted, Plaintiff has been
working diligently to identify the reduced scope of owners,
however due to the limited discovery that has been conducted
to date, the process has taken significantly longer than
6. Based on this delay, the Parties have agreed to extend the
deadline to file the SAC for thirty (30) days, until February
12, 2020. Additionally, based on prior stipulation,
Defendants' responses to the SAC will be due 30 days
after the SAC is filed (March 13, 2020).
7. This stipulation is not made for purposes of delay, but
rather to limit the scope of this case and maximize judicial