Filed: Apr. 11, 2019
Latest Update: Apr. 11, 2019
Summary: STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO FILE AMENDED COMPLAINT CARL W. HOFFMAN , Magistrate Judge . Plaintiffs Remark Holdings, Inc., and Kankan Limited, Defendant China Branding Group Limited (in Official Liquidation) acting through its Joint Official Liquidators, Hugh Dickson of Grant Thornton Specialist Services, and David Bennett of Grand Thornton Recovery and Reorganization Ltd. (the "Cayman Defendants"), and Defendant Adam Roseman hereby stipulate and agree that the
Summary: STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO FILE AMENDED COMPLAINT CARL W. HOFFMAN , Magistrate Judge . Plaintiffs Remark Holdings, Inc., and Kankan Limited, Defendant China Branding Group Limited (in Official Liquidation) acting through its Joint Official Liquidators, Hugh Dickson of Grant Thornton Specialist Services, and David Bennett of Grand Thornton Recovery and Reorganization Ltd. (the "Cayman Defendants"), and Defendant Adam Roseman hereby stipulate and agree that the d..
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STIPULATION AND [PROPOSED] ORDER FOR EXTENSION OF TIME TO FILE AMENDED COMPLAINT
CARL W. HOFFMAN, Magistrate Judge.
Plaintiffs Remark Holdings, Inc., and Kankan Limited, Defendant China Branding Group Limited (in Official Liquidation) acting through its Joint Official Liquidators, Hugh Dickson of Grant Thornton Specialist Services, and David Bennett of Grand Thornton Recovery and Reorganization Ltd. (the "Cayman Defendants"), and Defendant Adam Roseman hereby stipulate and agree that the deadline to file an Amended Complaint should be extended from April 9, 2019, until April 19, 2019. In support of this stipulation, the parties state as follows:
1. On March 26, 2019, the Court issued a Decision and Order granting in part and denying in part Roseman's motion to dismiss the Complaint, and granting Plaintiffs leave to file an Amended Complaint on or before April 9, 2019 (ECF No. 66). On April 1, 2019, the Cayman Defendants filed an opposition to Plaintiffs' motion to enforce the Stipulation for Settlement, with a response currently due April 8, 2019. These filings came at a time when Plaintiffs' counsel was overseas, and Remark's principal is currently overseas.
2. The additional time is not sought for purposes of delay, but, instead, is necessary for Plaintiffs and undersigned counsel to adequately supplement their allegations as required by the Court's Order.
3. This is the parties' first request to extend the time for Plaintiffs to file an Amended Complaint.
DATED: April 9, 2019
/s/ Kyle J. Kolb /s/ John F. LaSalle
Kyle C. Bisceglie (pro hac vice) Alan B. Vickery (pro hac vice)
Kyle J. Kolb (pro hac vice) John F. LaSalle (pro hac vice)
OLSHAN FROME WOLOSKY LLP BOIES SCHILLER FLEXNER LLP
1325 Avenue of the Americas 575 Lexington Avenue
New York, New York 10019 New York, New York 10022
Crane M. Pomerantz (NV Bar No. 14103) Richard J. Pocker (NV Bar No. 3568)
SKLAR WILLIAMS, PLLC BOIES SCHILLER FLEXNER LLP
410 S. Rampart Blvd., Suite 350 300 South Fourth Street, Suite 800
Las Vegas, Nevada 89145 Las Vegas, Nevada 89101
Attorneys for Plaintiffs REMARK Attorneys for Defendant ADAM ROSEMAN
HOLDINGS, INC. and KANKAN LIMITED
/s/ Robert D. Weber
Robert D. Weber (pro hac vice)
SHEPPARD, MULLIN, RICHTER &
HAMPTON LLP
1901 Avenue of the Stars, Suite 1600
Los Angeles, California 90067-6055
Robert J. Cassity (NV Bar No. 9779)
HOLLAND & HART LLP
9555 Hillwood Dr., Second Floor
Las Vegas, NV 89134
Attorneys for China Branding Group
Limited (In Official Liquidation) and its
Joint Official Liquidators Hugh Dickson
and David Bennett
IT IS SO ORDERED.
