Filed: Apr. 19, 2019
Latest Update: Apr. 19, 2019
Summary: STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO FILE RESPONSE TO COMPLAINT (FIRST REQUEST NANCY J. KOPPE , Magistrate Judge . Plaintiff SHAWN JAFFEE and DEREK KRITZ ("Plaintiffs"), by and through their counsel of record, Gabroy Law Offices and Theodora Oringher PC, and Defendant WYNN LAS VEGAS, LLC ("Defendant"), by and through its counsel of record, Brownstein Hyatt Farber Schreck, LLP, hereby stipulate and agree pursuant to Local Rule IA 6-1 to extend the deadline for Defend
Summary: STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO FILE RESPONSE TO COMPLAINT (FIRST REQUEST NANCY J. KOPPE , Magistrate Judge . Plaintiff SHAWN JAFFEE and DEREK KRITZ ("Plaintiffs"), by and through their counsel of record, Gabroy Law Offices and Theodora Oringher PC, and Defendant WYNN LAS VEGAS, LLC ("Defendant"), by and through its counsel of record, Brownstein Hyatt Farber Schreck, LLP, hereby stipulate and agree pursuant to Local Rule IA 6-1 to extend the deadline for Defenda..
More
STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANT TO FILE RESPONSE TO COMPLAINT
(FIRST REQUEST
NANCY J. KOPPE, Magistrate Judge.
Plaintiff SHAWN JAFFEE and DEREK KRITZ ("Plaintiffs"), by and through their counsel of record, Gabroy Law Offices and Theodora Oringher PC, and Defendant WYNN LAS VEGAS, LLC ("Defendant"), by and through its counsel of record, Brownstein Hyatt Farber Schreck, LLP, hereby stipulate and agree pursuant to Local Rule IA 6-1 to extend the deadline for Defendant to file its response to the Complaint and state as follows:
1. Defendant removed this case from state court to this Court on April 15, 2019.
2. Defendant's response to the Complaint is currently due on April 22, 2019.
3. This stipulation seeks to extend the deadline for Defendant to respond to the complaint up to and including May 22, 2019.
4. Good cause exists to grant this stipulation. Undersigned counsel was recently retained by Defendant in this action and requires additional time to review the Complaint and underlying facts and documentation, and to formulate an appropriate and informed response to the Complaint.
5. This stipulation is brought in good faith by both parties and not for purposes of delay.
6. No extension of time or continuance has previously been requested by Defendant.
7. By filing this stipulation, Defendant expressly reserves and does not waive its rights to assert any defense, including but not limited to Fed. R. Civ. P. 12(b) defenses.
IT IS THEREFORE STIPULATED by and among the parties that the deadline for Defendant to file a response to the Complaint is extended up to and including May 22, 2019.
CHRISTIAN J. GABROY, ESQ. TRAVIS F. CHANCE, ESQ.
christian@gabroy.com Nevada Bar No. 13800
tchance@bhfs.com
GABROY LAW OFFICES
170 South Green Valley Parkway, Suite 280 BROWNSTEIN HYATT FARBER
SCHRECK, LLP
Henderson, Nevada 89012 100 North City Parkway, Suite 1600
Telephone: (702) 259-7777 Las Vegas, NV 89106-4614
Facsimile: (702) 259-7704 Telephone: 702.382.2101
Facsimile: 702.382.8135
JON R. MOWER, ESQ.
Attorney for Defendant
jmower@tocounsel.com
THEODORA ORINGHER PC
535 Anton Boulevard, Ninth Floor
Costa Mesa, CA 92626-7109
Telephone: (714) 549-6200
Facsimile: (714) 549-6201
Attorneys for Plaintiffs
IT IS SO ORDERED.