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Motion For Extension of Time to Complete Discovery
Filed October 21, 2016

Motion For Extension of Time to Complete Discovery

COMES NOW, Nick and Donna Nickerson, respectfully request an extension of time to November 30, 2016, or whatever later time this Court deems appropriate, in which to present our evidence and argument to the District Court in compliance with the remand order issued by the Montana Supreme Court. This request is necessary because HSBC, by and through their alleged Servicer Wells Fargo, has blocked our access to discovery that demonstrates Wells Fargo’s intentional prevention of performance, corroborates our comprehensive prevention of performance claims, and further demonstrates the banks wrongfully violated their agreements and Montana law. This request allows us to pursue and compel other corroborating evidence to defend our rights against this unlawful and unjust seizure of our property and equity.

We apologize if we are inappropriately approaching the Court with this request, but we are unsure whether the Supreme Court intended for us to approach you or for us to wait until you approached us regarding this extension. Since we have not heard from the Court regarding this matter, and would like to continue discovery so we can secure justice regarding our property, we decided to go ahead and approach you with our request directly.

This motion is supported by a brief submitted in conjunction with this motion.



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