The Erection Company v. Archer Western Contractors, LLC et al

Filing 247

ORDER Granting 246 Motion to Extend Time. Proposed Joint Pretrial Order due by 7/7/2015. Signed by Judge Miranda M. Du on 5/26/2015. (Copies have been distributed pursuant to the NEF - DC)

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KURT C. FAUX
Nevada Bar No. 003407
WILLI H. SIEPMANN
Nevada Bar No. 002478
THE FAUX LAW GROUP
1540 W. Warm Springs Road, #100
Henderson, Nevada 89014
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
Attorneys for Archer Western Contractors, LLC and
Travelers Surety and Casualty Company of America (Bond No. 105478077

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

THE FAUX LAW GROUP

1540 W WARM SPRINGS ROAD, SUITE 100
HENDERSON, NEVADA 89014
TEL [phone]

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THE ERECTION COMPANY, INC., a
Washington Corporation

CASE NO. 2:12-cv-00612-MMD-NJK
JOINT MOTION AND
ORDER FOR AN EXTENSION OF TIME
FOR THE PARTIES TO FILE A JOINT
PRETRIAL ORDER WITH THE COURT

Plaintiff,

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vs.

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ARCHER WESTERN CONTRACTORS,
LLC, a Delaware foreign limited-liability
company; POSTEL ERECTION GROUP,
LLC, a domestic limited liability company;
POSTEL WEST, INC., an Arizona
corporation; POSTEL INDUSTRIES, INC., an
unknown entity; TRAVELERS CASUALTY
AND SURETY COMPANY OF AMERICA;
DOES I through X; ROES XI through XX

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(Second Request)

Defendants.

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AND RELATED ACTIONS

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Plaintiff, The Erection Company (“TEC), and Defendants, Archer Western Contractors, LLC

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(“AWC”), Travelers Casualty and Surety Company of America (“Travelers”) and Postel Industries,

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Inc., (“Postel”), by and through their counsel of record, hereby jointly move for an Order extending

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the deadline in which the parties have to file a Joint Pretrial Order with the Court. Pursuant to the
Court’s Minute Order filed March 19, 2015, the Court ordered that the parties file a Joint Pretrial
Order with the Court. (See Dkt. #245.) The parties hereto request a further thirty day extension of that

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deadline to July 7, 2015 for the following reasons: (1) The parties have found it impossible to schedule

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a meeting of counsel to discuss the stipulated facts, stipulated documents, objections to documents and

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deposition testimony, etc required by the Joint Pre Trial Order because of previously scheduled

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vacations and calendar conflicts; (2) The sheer volume of potential trial documents and deposition

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testimony warrants an exchange of proposed exhibits, facts, issues of law, and deposition testimony

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prior to any meeting of counsel. The brief extension of the deadline to file the pre trial order will allow

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the parties to exchange such documents, briefs and evidence; and (3) The parties intend to discuss

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duringthe brief extension whether to exclude the respective sureties from the trial pursuant to a

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stipulation, thereby streamlining the trial herin. Consequently, the parties jointly request an Order from

THE FAUX LAW GROUP

1540 W WARM SPRINGS ROAD, SUITE 100
HENDERSON, NEVADA 89014
TEL [phone]

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the Court extending the deadline in which the parties have to file their Joint Pretrial Order from June

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5, 2015 until July 7, 2015.

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DATED this 21st day of May, 2015.
THE FAUX LAW GROUP

KEMP, JONES & COULTHARD, LLP

/s/ Kurt C. Faux, Esq.
Kurt C. Faux, Esq.
Nevada Bar No. 003407
Willi H. Siepmann, Esq.
State Bar No. 002478
1540 W. Warm Springs Road, #100
Henderson, Nevada 89014
Counsel for Archer Western Contractors, LLC
and Travelers Surety and Casualty Company of
America (Bond No. 105478077

/s/ Spencer H. Gunnerson, Esq. (by permission)
Spencer H. Gunnerson, Esq.
State Bar No. 008810
Nathanael R. Rulis, Esq.
State Bar No. 011259
3800 Howard Hughes Parkway
Las Vegas, Nevada 89169
Counsel for The Erection Company

THE WILLIARD LAW FIRM, L.P.

WATT, TIEDER, HOFFAR
& FITZGERALD, LLP

/s/ Steve M. Williard, Esq. (by permission)
Steve M. Williard, Esq.
Texas State Bar No. 00788684
1920 N. Memorial Way
Houston, Texas 77007
[phone]
Counsel for Postel Industries, Inc.

/s/ David R. Johnson, Esq. (by permission)
David R. Johnson, Esq.
Nevada Bar No. 6696
Jared M. Sechrist, Esq.
Nevada Bar No. 10439
3993 Howard Hughes Parkway, Suite 400
Las Vegas, Nevada 89169
Counsel for Travelers Casualty & Surety Co.
(Bond No. 105707041)

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The Erection Company, Inc. v. Archer Western Contractors, LLC, et al.
United States District Court, District Of Nevada Case No. 2:12-cv-00612-MMD-NJK
Joint Motion and Proposed Order for an Extension of Time for the
Parties to File a Joint Pretrial Order with the Court (Second Request)

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ORDER
IT IS SO ORDERED:

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_________________________________
United States District Court Judge
May 26, 2015
DATED:__________________________

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THE FAUX LAW GROUP

1540 W WARM SPRINGS ROAD, SUITE 100
HENDERSON, NEVADA 89014
TEL [phone]

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