Filed: Jun. 27, 2019
Latest Update: Jun. 27, 2019
Summary: ORDER RE: STIPULATION AND [PROPOSED] ORDER TO EXTEND BRIEFING SCHEDULE ON DEFENDANTS' MOTION TO DISMISS FIRST AMENDED COMPLAINT MIRANDA M. DU , District Judge . Plaintiffs Noel C. Murray, Dr. Swarna Perera, and Joyce E. Friedman ("Plaintiffs"), by and through their counsel of record, the Law Office of Hayes & Welsh, the Law Office of Christopher J. Gray, P.C., and the Law Offices of Joshua B. Kons, LLC, and Defendant Provident Trust Group, LLC, by and through its counsel of record, Greenber
Summary: ORDER RE: STIPULATION AND [PROPOSED] ORDER TO EXTEND BRIEFING SCHEDULE ON DEFENDANTS' MOTION TO DISMISS FIRST AMENDED COMPLAINT MIRANDA M. DU , District Judge . Plaintiffs Noel C. Murray, Dr. Swarna Perera, and Joyce E. Friedman ("Plaintiffs"), by and through their counsel of record, the Law Office of Hayes & Welsh, the Law Office of Christopher J. Gray, P.C., and the Law Offices of Joshua B. Kons, LLC, and Defendant Provident Trust Group, LLC, by and through its counsel of record, Greenberg..
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ORDER RE: STIPULATION AND [PROPOSED] ORDER TO EXTEND BRIEFING SCHEDULE ON DEFENDANTS' MOTION TO DISMISS FIRST AMENDED COMPLAINT
MIRANDA M. DU, District Judge.
Plaintiffs Noel C. Murray, Dr. Swarna Perera, and Joyce E. Friedman ("Plaintiffs"), by and through their counsel of record, the Law Office of Hayes & Welsh, the Law Office of Christopher J. Gray, P.C., and the Law Offices of Joshua B. Kons, LLC, and Defendant Provident Trust Group, LLC, by and through its counsel of record, Greenberg Traurig, LLP, hereby stipulate and request that the Court extend the time by which Plaintiffs must file papers in opposition to Defendant's Motion to Dismiss Plaintiffs' First Amended Complaint (DE 49, the "Motion to Dismiss") until and including, July 26, 2019. This Stipulation is made and based upon the following:
1. Plaintiffs filed their First Amended Class Action Complaint on May 8, 2019, in which they allege Defendant breached contractual duties as custodian of Plaintiffs' Individual Retirement Accounts. [ECF No. 46]. Plaintiffs seek certification to represent a class of similarly situated individuals across the country. Id.
2. Defendant filed the Motion to Dismiss on June 21, 2019 and Plaintiffs' opposition papers are currently due on July 5, 2019.
3. Counsel for Plaintiffs has requested additional time to evaluate the Motion to Dismiss and prepare a response, taking into account the exercise of due diligence. Counsel for Defendant has agreed to this request.
4. In light of the foregoing, the parties agree that Plaintiffs shall have up to, and including, July 26, 2019, to respond to the Motion to Dismiss.
5. This is the first request for an extension of time in this regard. This Stipulation is entered into in good faith and not for purposes of delay.
DATED: June 25, 2019 DATED: June 25, 2019
THE LAW OFFICE OF HAYES & WELSH GREENBERG TRAURIG, LLP
Martin L. Welsh, Esq. (Nevada Bar No. 8720) Mark E. Ferrario, Esq. (Nevada Bar. No. 1625)
199 N. Arroyo Grande Blvd., Suite 200 Jason K. Hicks, Esq. (Nevada Bar No. 13149)
Henderson, Nevada 89074 10846 Griffith Peak Drive, Ste. 600
Telephone: (702) 434-3444 Las Vegas, Nevada 89135
Email: mwelsh@lvlaw.com Telephone: (702) 792-3773
Email: ferrariom@gtlaw.com
Email: hicksjk@gtlaw.com
Attorneys for Defendant
LAW OFFICE OF CHRISTOPHER J. GRAY P.C.
Christopher J. Gray, Esq. (Pro Hac Vice)
360 Lexington Avenue, 14th Floor
New York, New York 10017
Telephone: (866) 966-9598
Email: chris@investorlawyers.net
Email: mike@investorlawyers.net
LAW OFFICES OF JOSHUA B. KONS, LLC
Joshua B. Kons, Esq. (Pro Hac Vice)
100 Pearl Street, 14th Floor
Hartford, CT 06103
Telephone: (860) 920-5181
Facsimile: (860) 920-5174
Email: joshuakons@konslaw.com
Attorneys for Plaintiffs
IT IS SO ORDERED.
