Filed: May 07, 2019
Latest Update: May 07, 2019
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR PLAINTIFFS TO RESPOND TO DEFENDANTS' MOTION TO DISMISS AND MOTION TO STAY GLORIA M. NAVARRO , Chief District Judge . Plaintiffs TRUSTEES OF THE BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 DEFINED CONTRIBUTION PENSION TRUST FOR SOUTHERN NEVADA; TRUSTEES OF THE BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 HEALTH BENEFITS FUND; TRUSTEES OF THE BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 VACATION FUND; BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 NE
Summary: STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR PLAINTIFFS TO RESPOND TO DEFENDANTS' MOTION TO DISMISS AND MOTION TO STAY GLORIA M. NAVARRO , Chief District Judge . Plaintiffs TRUSTEES OF THE BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 DEFINED CONTRIBUTION PENSION TRUST FOR SOUTHERN NEVADA; TRUSTEES OF THE BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 HEALTH BENEFITS FUND; TRUSTEES OF THE BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 VACATION FUND; BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 NEV..
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STIPULATION AND [PROPOSED] ORDER TO EXTEND TIME FOR PLAINTIFFS TO RESPOND TO DEFENDANTS' MOTION TO DISMISS AND MOTION TO STAY
GLORIA M. NAVARRO, Chief District Judge.
Plaintiffs TRUSTEES OF THE BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 DEFINED CONTRIBUTION PENSION TRUST FOR SOUTHERN NEVADA; TRUSTEES OF THE BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 HEALTH BENEFITS FUND; TRUSTEES OF THE BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 VACATION FUND; BRICKLAYERS & ALLIED CRAFTWORKERS LOCAL 13 NEVADA; TRUSTEES OF THE BRICKLAYERS & TROWEL TRADES INTERNATIONAL PENSION FUND; TRUSTEES OF THE BRICKLAYERS & TROWEL TRADES INTERNATIONAL HEALTH FUND; and TRUSTEES OF THE INTERNATIONAL MASONRY INSTITUTE (hereinafter referred to collectively as "Plaintiffs"), by and through their counsel of record, The Urban Law Firm, and PEGASUS MARBLE, INC. and GAGIK ZARGARYAN (hereinafter referred to collectively as "Defendants"), by and through their counsel of record, Law Office of Daniel Marks, hereby stipulate to extend the time for Plaintiffs to respond to Defendants' Motion to Dismiss Third Claim and Motion to Stay through the date of May 28, 2019, which is a 20 day extension of the current deadline.
Defendants' Motion to Dismiss Third Claim and Motion to Stay were filed on April 24, 2019. ECF Nos. 11-12. The Plaintiffs' response is currently due May 8, 2019.
Due to travel schedule of Plaintiffs' counsel and prior scheduled court hearings in another state, Plaintiffs' counsel needs an extension of time—until May 28, 2019—to prepare the Plaintiffs' response to Defendants' Motion to Dismiss Third Claim and Motion to Stay. Plaintiffs' counsel has conferred with Defendants' counsel and Defendants' counsel has stated that he agrees to the extension request.
This request is made in good faith and is not made for any improper purpose or to delay these proceedings.
Dated: May 6, 2019 THE URBAN LAW FIRM
By: /s/ Nathan R. Ring
MICHAEL A. URBAN, Nevada Bar No. 3875
NATHAN R. RING, Nevada State Bar No. 12078
4270 S. Decatur Blvd., Suite A-9
Las Vegas, Nevada 89103
Counsel for Plaintiffs
Dated: May 6, 2019 LAW OFFICE OF DANIEL MARKS
By: /s/ Adam Levine
DANIEL MARKS, Nevada State Bar No. 002003
office@danielmarks.net
ADAM LEVINE, ESQ.
Nevada State Bar No. 004673
alevine@danielmarks.net
610 South Ninth Street
Las Vegas, Nevada 89101
Attorneys for Defendants
ORDER
IT IS HEREBY ORDERED that the above Stipulation to Extend Time, (ECF No. 13), is GRANTED.
