GenX Processors Mauritius Limited v. Jackson et al

Filing 78

ORDER Granting 77 Stipulation to Extend Time. Show Cause Hearing reset for 3/12/2019 at 11:30 AM in LV Courtroom 3B before Magistrate Judge Peggy A. Leen. Signed by Magistrate Judge Peggy A. Leen on 2/1/2019. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:14-cv-01938-APG-PAL Document 77 Filed 01/31/19 Page 1 of 3

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LARSON A. WELSH, ESQ.
Nevada Bar No. 12517
LAW OFFICE OF HAYES & WELSH
199 North Arroyo Grande Blvd., Suite 200
Henderson, Nevada 89074
Phone: [phone]
Fax: [phone]
Email: [e-mail]
Attorneys for Nonparties Vinum, Inc.,
Caymus Limited Partnership, Ecommerce
Marketing, Inc., T-3 Media, LLC, Wild West
Media, LLC, Pacific Coastal, LLC, and
Consumercoupons.com, Inc.

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UNITED STATES DISTRICT COURT

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A PROFESSIONAL CORPORATION

199 NORTH ARROYO GRANDE BLVB., SUITE 200
HENDERSON, NEVADA 89074
[phone] FAX [phone]

LAW OFFICE OF

HAYES & WELSH

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DISTRICT OF NEVADA
GENX PROCESSORS MAURITIUS
LIMITED,

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Case No. 2:14-cv-01938-APG-PAL

Plaintiff,
v.
MATTHEW G. JACKSON a/k/a MATT G.
JACKSON; SYMMETRIC SYSTEMS, LLC;
SYMMETRIC SYSTEMS, INC. f/k/a
SYMMETRIC SYSTEMS, LLC; and DOES I
through X,

STIPULATION AND ORDER TO
EXTEND SHOW CAUSE HEARING
(First Joint Request to Extend Show
Cause Hearing)1

Defendants.

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Nonparties Vinum, Inc., Caymus Limited Partnership, Ecommerce Marketing, Inc., T-3

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Media, LLC, Wild West Media, LLC, Pacific Coastal, LLC, and Consumercoupons.com, Inc.

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(collectively referred to as “Nonparties”), by and through their attorney, the Law Office of Hayes

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& Welsh, and Plaintiff, GenX Processors Mauritius Limited (“Plaintiff” and collectively with

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Nonparties, the “Parties”), by and through its attorney of record, The Dean Legal Group, Ltd.,

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hereby submit this Stipulation and Order to Extend Show Cause Hearing. The Show Cause

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Hearing is presently scheduled to occur on February 5, 2019 at 10:30 a.m. ECF No. 76.

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…

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1 For purposes of clarity, Nonparties previously requested to continue the Show Cause Hearing on an Emergency
Basis. ECF No. 75. Nonparties’ Emergency Motion (ECF No. 75) was granted and the Show Cause Hearing was
moved from January 8, 2019 to the presently scheduled date of February 5, 2019. See ECF No. 76.

Case 2:14-cv-01938-APG-PAL Document 77 Filed 01/31/19 Page 2 of 3

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This Stipulation and Order is submitted in compliance with LR IA 6-1, LR IA 6-2 and

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LR 26-4. As the present request to extend a deadline is made within 21 days before the Show

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Cause Hearing, the Parties submit that the following constitutes a showing of good cause. See

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LR 26-4.

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On December 18, 2018, the Court set a Hearing on Plaintiff’s Motion for Order to Show

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Cause (ECF No. 65). The Hearing was set for January 8, 2019 at 10:30 a.m. and required the

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personal appearance of Nonparties’ representative Matthew G. Jackson. ECF No. 74.

A PROFESSIONAL CORPORATION

(ECF No. 75). In their Emergency Motion to Continue, the Nonparties also stated the following:

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199 NORTH ARROYO GRANDE BLVB., SUITE 200
HENDERSON, NEVADA 89074
[phone] FAX [phone]

Hearing based on personal circumstances of Nonparties’ representative Matthew G. Jackson.

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LAW OFFICE OF

On January 2, 2019, Nonparties filed an Emergency Motion to Continue the Show Cause

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HAYES & WELSH

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Further, granting a continuance until February 5, 2019, would allow an
opportunity for Nonparties to accept one of Plaintiff’s offer and provide
Nonparties an opportunity to perform on the first of two settlement payments to
Plaintiff. A step, which if achieved, would bring this matter one final payment
away from a full and complete resolution.
See e.g., id. at p. 8, lln. 8-11.

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As contemplated in the Emergency Motion to Continue, the Parties subsequently entered

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into a Mutual Release and Settlement Agreement (“Settlement Agreement”). The terms of the

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Settlement Agreement are confidential, but the Parties submit that Nonparties have performed

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on the first of two settlement payments to Plaintiff. Accordingly, the Parties respectfully request

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this Court continue the Show Cause Hearing currently scheduled for February 5, 2019 (ECF No.

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76) until a date after March 8, 2019. If Nonparties perform on the second and final payment to

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Plaintiff, a satisfaction of judgment will be filed, ending this controversy in its entirety, including

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the need to hold a show cause hearing. If Nonparties fail to perform on the second and final

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payment to Plaintiff, Nonparties will have presumably breached the confidential settlement

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agreement and the post-March 8, 2019 Show Cause Hearing will move forward.

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The Parties submit this stipulation and order diminishes the likelihood for further judicial

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intervention in this matter. Further this stipulation and order minimizes the use of judicial

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resources, as well as the resources of the Parties.

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…
Page 2 of 3

Case 2:14-cv-01938-APG-PAL Document 77 Filed 01/31/19 Page 3 of 3

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Dated this 31st day of January 2019

Dated this 31st day of January 2019

THE LAW OFFICE OF HAYES & WELSH

THE DEAN LEGAL GROUP, LTD.

By:/s/ Larson A. Welsh
LARSON A. WELSH, ESQ.
Nevada Bar No. 12517
199 North Arroyo Grande Blvd., Suite 200
Henderson, Nevada 89074
Tel: [phone]
Fax: [phone]
Attorneys for Nonparties Vinum, Inc.,
Caymus Limited Partnership, Ecommerce
Marketing, Inc., T-3 Media, LLC, Wild
West Media, LLC, Pacific Coastal, LLC,
And Consumercoupons.com, Inc.

By:/s/ Aaron R. Dean
AARON R. DEAN, ESQ.
Nevada Bar No. 9541
721 S. 6TH Street
Las Vegas, Nevada 89101
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff

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A PROFESSIONAL CORPORATION

199 NORTH ARROYO GRANDE BLVB., SUITE 200
HENDERSON, NEVADA 89074
[phone] FAX [phone]

LAW OFFICE OF

HAYES & WELSH

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IT IS SO ORDERED that the Order to Show Cause Hearing currently set for
February 5, 2019, is VACATED and CONTINUED to March 12, 2019 at 11:30 a.m.
IT IS SO ORDERED:
in Courtroom 3B.

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UNITED STATES MAGISTRATE JUDGE

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DATED:

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Page 3 of 3

February 1, 2019