Filed: Apr. 26, 2016
Latest Update: Apr. 26, 2016
Summary: STIPULATION AND ORDER FOR (1) EXTENSION OF TIME TO RESPOND TO COMPLAINT AND (2) BRIEFING SCHEDULE ON MOTION FOR PRELIMINARY INJUNCTION (FIRST REQUEST RICHARD F. BOULWARE II , District Judge . Tutoring Club, LLC ("Plaintiff"), by and through its counsel, the law firm of Howard & Howard Attorneys PLLC, and Michael C. Flynn ("Flynn"), by and through his counsel, the law firm of Dickinson Wright PLLC and the Law Offices of Thomas E. Francis, P.C., pursuant to Local Rule 6-1 hereby stipulate an
Summary: STIPULATION AND ORDER FOR (1) EXTENSION OF TIME TO RESPOND TO COMPLAINT AND (2) BRIEFING SCHEDULE ON MOTION FOR PRELIMINARY INJUNCTION (FIRST REQUEST RICHARD F. BOULWARE II , District Judge . Tutoring Club, LLC ("Plaintiff"), by and through its counsel, the law firm of Howard & Howard Attorneys PLLC, and Michael C. Flynn ("Flynn"), by and through his counsel, the law firm of Dickinson Wright PLLC and the Law Offices of Thomas E. Francis, P.C., pursuant to Local Rule 6-1 hereby stipulate and..
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STIPULATION AND ORDER FOR (1) EXTENSION OF TIME TO RESPOND TO COMPLAINT AND (2) BRIEFING SCHEDULE ON MOTION FOR PRELIMINARY INJUNCTION
(FIRST REQUEST
RICHARD F. BOULWARE II, District Judge.
Tutoring Club, LLC ("Plaintiff"), by and through its counsel, the law firm of Howard & Howard Attorneys PLLC, and Michael C. Flynn ("Flynn"), by and through his counsel, the law firm of Dickinson Wright PLLC and the Law Offices of Thomas E. Francis, P.C., pursuant to Local Rule 6-1 hereby stipulate and agree as follows:
WHEREAS, on or about March 8, 2016, Plaintiff filed a Complaint against Flynn in the Eighth Judicial District Court, Clark County, Nevada bearing Case No. A-16-733114-B (the "Complaint").
WHEREAS, on or about March 23, 2016, Plaintiff filed a Motion for Preliminary Injunction ("Motion").
WHEREAS, on or about April 9, 2016, Flynn filed a Petition for Removal removing the matter to this Court [Dkt. 1].
WHEREAS, counsel for the parties have conferred and have come to an agreement regarding (1) the deadline for responding to the Complaint and (2) for completing the briefing on the Motion.
Now, therefore, based upon the following, the parties, by and through their counsel, hereby stipulate to the following deadlines with respect to the Complaint and the Motion:
1. Flynn shall have to and including Friday, April 22, 2016, to file a responsive pleading to the Complaint.
2. Flynn shall have to and including Monday, April 18, 2016, to file his opposition to the Motion.
3. Plaintiff shall have to and including Wednesday, April 27, 2016, to file its reply in support of the Motion.
4. The extensions referenced above are sought in good faith to, among other things, accommodate the schedules of the parties and their counsel.
5. There have been no previous extensions requested or granted to either party with respect to the Complaint or the Motion.
6. Neither this stipulation nor anything stated herein shall be construed as a waiver or concession or any arguments or objections regarding the propriety of the removal of this action.
IT IS SO STIPULATED.
IT IS SO ORDERED.
