Federal Trade Commission v. AMG Services, Inc. et al

Filing 919

ORDER Granting 915 Motion to Extend Time to Respond/Reply re 899 Motion for Sanctions re Discovery and 900 Motion for Summary Judgment. Responses due by 2/26/2016. Replies due by 3/18/2016. Signed by Chief Judge Gloria M. Navarro on 2/3/16. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:12-cv-00536-GMN-VCF Document 915 Filed 01/21/16 Page 1 of 3

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DANIEL G. BOGDEN
United States Attorney
District of Nevada
BLAINE T. WELSH
Assistant United States Attorney
Nevada Bar. No. 4790
333 Las Vegas Blvd. South, Suite 5000
Las Vegas, Nevada 89101
Phone: [phone]
Facsimile: [phone]
Email: [e-mail]
JONATHAN E. NUECHTERLEIN
General Counsel
NIKHIL SINGHVI
JASON D. SCHALL
HELEN P. WONG
IOANA RUSU
LaSHAWN M. JOHNSON
COURTNEY A. ESTEP
THOMAS KANE
Federal Trade Commission
600 Pennsylvania Avenue, NW
Mailstop CC-10232
Washington, D.C. 20580
Phone: [phone] (Singhvi)
Facsimile: [phone]
Email: [e-mail] (Singhvi); [e-mail] (Schall)
Attorneys for Plaintiff Federal Trade Commission

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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FEDERAL TRADE COMMISSION,
Plaintiff,

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v.
AMG Services, Inc. et al.,

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Defendants, and

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Case No. 2:12-cv-536

Park 269 LLC, et al.,
Relief Defendants.

STIPULATION FOR BRIEFING
SCHEDULE FOR RELIEF
DEFENDANTS’ MOTIONS FOR
DISCOVERY SANCTIONS AND
SUMMARY JUDGMENT

Case 2:12-cv-00536-GMN-VCF Document 915 Filed 01/21/16 Page 2 of 3

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Plaintiff Federal Trade Commission (“FTC”) and Kim Tucker and Park 269, LLC (the “Relief

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Defendants”) jointly move the Court for an order setting forth a briefing schedule for the Relief

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Defendants’ motions for discovery sanctions (ECF No. 899) and for summary judgment (ECF No 900)

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(collectively, the “Motions”):

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1. On December 9, 2015, the Court entered the parties’ stipulated order for a briefing schedule to

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govern dispositive motions briefing. (ECF No. 897 at 3.) The order provided that dispositive

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motions would be filed by January 20, 2016, with responding memoranda filed on February 26,

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2016, and reply memoranda filed on March 18, 2016. (Id. at 1.)

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2. On January 19, 2016, the Relief Defendants filed a motion for discovery sanctions (ECF No.
899) and a motion for summary judgment (ECF No. 900.)

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3. The Motions are identical.

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4. Absent relief from this Court, the FTC would be required to respond to the Relief Defendants’

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discovery motion by February 5, 2016 (per LR 7-2(b) and Fed. R. Civ. P. 6(d)), and would be

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required to respond to the Relief Defendants’ summary judgment motion on February 26, 2016

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(per the briefing order, ECF No. 897). Absent relief from this Court, the Relief Defendants’

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reply memoranda in support of their Motions would also be separated and filed at different

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times.

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5. The FTC and the Relief Defendants have conferred and agree that, because the Motions are

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identical, and to avoid piecemeal briefing, the parties should file combined responding and reply

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memoranda and that the existing summary judgment briefing schedule entered by the Court

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(ECF No. 897) should govern both Motions.

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Wherefore, the parties jointly request a briefing schedule for the Relief Defendants’ motion for discovery

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sanctions (ECF No. 899) and motion for summary judgment (ECF No. 900) as follows:

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a. The FTC shall file a combined memorandum responding to both Motions on February
26, 2016.
b. The Relief Defendants shall file a combined reply memorandum in support of both
Motions on March 18, 2016.

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Case 2:12-cv-00536-GMN-VCF Document 915 Filed 01/21/16 Page 3 of 3

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Dated: January 21, 2016

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/s Nikhil Singhvi

/s Linda McFee

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____________________________________
Nikhil Singhvi
Federal Trade Commission
600 Pennsylvania Ave., NW
Mailstop CC-10232
Washington, DC 20580
[e-mail]
Tel. [phone]
Fax [phone]

____________________________________
Linda McFee
McDowell, Rice, Smith & Buchanan, P.C.
605 W. 47th Street, Suite 350
Kansas City, Missouri 64112
[e-mail]
Tel. [phone]
Fax: [phone]

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Attorney for Kim Tucker and Park 269, LLC
Attorney for Plaintiff Federal Trade Commission

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IT IS SO ORDERED:

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________________________________________

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UNITED STATES DISTRICT JUDGE

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February 3, 2016
Dated: ___________________________________

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