Filed: Nov. 07, 2019
Latest Update: Nov. 07, 2019
Summary: STIPULATION TO FILE FIRST AMENDED COMPLAINT WILLIAM G. COBB , Magistrate Judge . Plaintiff, Nevada Gold Mines, LLC ("NGM") a Delaware limited liability company and Defendants Imatech Systems Cyprus PTY Ltd dba Armorpipe Technologies ("Imatech Cyprus") and International Materials & Technology PTY Limited dba Imatech ("IM&T"), without waiver of any defenses hereby stipulate as follows: 1. NGM filed its original complaint on December 4, 2018. 2. NGM now seeks to file a First Amended Compla
Summary: STIPULATION TO FILE FIRST AMENDED COMPLAINT WILLIAM G. COBB , Magistrate Judge . Plaintiff, Nevada Gold Mines, LLC ("NGM") a Delaware limited liability company and Defendants Imatech Systems Cyprus PTY Ltd dba Armorpipe Technologies ("Imatech Cyprus") and International Materials & Technology PTY Limited dba Imatech ("IM&T"), without waiver of any defenses hereby stipulate as follows: 1. NGM filed its original complaint on December 4, 2018. 2. NGM now seeks to file a First Amended Complai..
More
STIPULATION TO FILE FIRST AMENDED COMPLAINT
WILLIAM G. COBB, Magistrate Judge.
Plaintiff, Nevada Gold Mines, LLC ("NGM") a Delaware limited liability company and Defendants Imatech Systems Cyprus PTY Ltd dba Armorpipe™ Technologies ("Imatech Cyprus") and International Materials & Technology PTY Limited dba Imatech ("IM&T"), without waiver of any defenses hereby stipulate as follows:
1. NGM filed its original complaint on December 4, 2018.
2. NGM now seeks to file a First Amended Complaint that includes claims against additional entities Imatech Manufacturing Centre Pty Ltd. and Armorpipe Pty Ltd., as well as additional factual allegations to support its claims.
3. Without waiving any jurisdictional arguments or other defenses and pursuant to FRCP 15(a)(2), Imatech Cyprus and IM&T consent to NGM filings its First Amended Complaint, a copy of which is attached hereto as Exhibit 1.
4. In light of prior rulings in this matter in connection with service of process issues, Counsel for Imatech Cyprus and IM&T recognize that it is highly likely that the Court would ultimately issue an Order for alternative service by e-mail if service through the Hague Convention proved difficult. With the express understanding that all defenses other than service of process are reserved, service of the First Amended Complaint with respect to all Defendants will be effectuated by e-mail to jwhitmire@santoronevada.com.
RESPECTFULLY SUBMITTED this 6th day of November, 2019.
McDONALD CARANO LLP SANTORO WHITMIRE
/s/ Sarah Ferguson /s/ James E. Whitmire
Matthew Addison, Esq. (NSBN 4201) James E. Whitmire, Esq. (NSBN 6533)
Sylvia Harrison, Esq. (NSBN 4106) 10100 W. Charleston Blvd., Suite 250
Sarah Ferguson, Esq. (NSBN 14515) Las Vegas, NV 89135
100 West Liberty Street. 10th Floor Telephone: (702) 948-8771
Reno, NV 89501 Facsimile: (702) 948-8773
Telephone: (775) 788-2000 jwhitmire@santoronevada.com
Facsimile: (775) 788-2020 Attorneys for Defendants Imatech Systems
maddison@mcdonaldcarano.com Cyprus PTY Ltd dba Armorpipe™
sharrison@mcdonaldcarano.com Technologies and International Materials &
sferguson@mcdonaldcarano.com Technology PTY Limited dba Imatech
Attorneys for Plaintiff
IT IS SO ORDERED.
