Metro PCS v. A2Z Connection, LLC et al

Filing 176

ORDER granting 174 Stipulation; Re: 166 Motion to Dismiss, 157 Motion for Protective Order, 145 Motion to Quash, 153 Motion to Compel, 168 Motion to Seal, 167 Motion to Compel. Responses for 166 Motion due by 12/6/2019. Responses for 167 and 168 due by 12/11/2019. Motion Hearings reset for 1/13/2020 at 01:00 PM in LV Courtroom 3A before Magistrate Judge Daniel J. Albregts. Signed by Magistrate Judge Daniel J. Albregts on 11/14/2019. (Copies have been distributed pursuant to the NEF - JM)

Case 2:15-cv-01412-JAD-DJA Document 174 Filed 11/12/19 Page 1 of 4

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THE WRIGHT LAW GROUP P.C.
2340 Paseo Del Prado, Suite D-305
Las Vegas, Nevada 89102
Tel: [phone] Fax: [phone]

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JOHN HENRY WRIGHT, ESQ.
Nevada Bar No. 6182
CHRISTOPHER B. PHILLIPS, ESQ.
Nevada Bar No. 14600
AMY J. SMITH, ESQ.
Nevada Bar No. 14954
THE WRIGHT LAW GROUP, P.C.
2340 Paseo Del Prado, Suite D-305
Las Vegas, Nevada 89102
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
[e-mail]
[e-mail]
Attorneys for Defendants
AMIR QURESHI a/k/a AMIER QURESHI, a/k/a
AMIER I. QURESHI, a/k/a AMIER F.
QURESHI, SR.; ASIM QURESHI a/k/a
ALEX QURESHI, a/k/a AZIM QURESHI
a/k/a AZIM DeDREAM, and SEHER
QURESHI

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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METROPCS, a brand of T-MOBILE USA,
INC., a Delaware Corporation,
Plaintiff,

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vs.

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A2Z CONNECTION, LLC, a Nevada
limited liability corporation; A2Z LLC, a
Nevada limited liability corporation; AMIR
QURESHI a/k/a AMIER QURESHI, a/k/a
AMIER I. QURESHI, a/k/a AMIER F.
QURESHI, SR.; ASIM QURESHI a/k/a
ALEX QURESHI, a/k/a AZIM QURESHI
a/k/a AZIM DeDREAM, and SEHER
QURESHI,

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Case No. 2:15-cv-01412-JAD-DJA
STIPULATION AND PROPOSED
ORDER TO MODIFY BRIEFING
SCHEDULE ON PENDING MOTIONS
[ECF 166] [ECF 167] AND [ECF 168]
AND CONTINUE HEARING SET BY
MAGISTRATE

Defendants.
Plaintiff, METROPCS a brand of T-MOBILE USA, INC., a Delaware Corporation
(“METROPCS”), and Defendants, AMIR QURESHI a/k/a AMIER QURESHI, a/k/a AMIER I.
QURESHI, a/k/a AMIER F. QURESHI, SR.; ASIM QURESHI a/k/a ALEX QURESHI; a/k/a
AZIM QURESHI, a/k/a AZIM DeDREAM; and SEHER QURESHI (“Defendants”) (hereinafter

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Page 1 of 4

Case 2:15-cv-01412-JAD-DJA Document 174 Filed 11/12/19 Page 2 of 4

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collectively referred to as the “Parties”), by and through their undersigned counsel, and pursuant

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to Local Rule IA 6-1 and 6-2, hereby jointly stipulate to an extension up to and including

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November 15, 2019 for Plaintiff to file their Opposition to Defendants’ Motion to Dismiss, in Part,

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Plaintiff’s Complaint [ECF No. 166]; an extension up to and including December 6, 2019 for

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Defendants to file their Opposition to Plaintiff’s Motion to Compel Defendants to Produce

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Electronic Discovery and for Sanctions and Memorandum of Law [ECF No. 167]; and an extension

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up to and including December 11, 2019 for Defendants to file their Opposition to Plaintiff’s Motion

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for Leave to File Documents Under Seal [ECF No. 168] and states as follows:

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THE WRIGHT LAW GROUP P.C.
2340 Paseo Del Prado, Suite D-305
Las Vegas, Nevada 89102
Tel: [phone] Fax: [phone]

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1.

This extension is requested because the Parties are actively involved in settlement

discussion.
2.

On October 18, 2019, Defendants filed their Motion to Dismiss, in Part, Plaintiff’s

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Complaint [ECF 166]. Plaintiff’s Opposition to Defendants’ Motion to Dismiss is currently due

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November 15, 2019.

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3.

On October 23, 2019, Plaintiff filed its Motion to Compel Defendants to Produce

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Electronic Discovery and for Sanctions and Incorporated Memorandum of Law [ECF 167].

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Defendants’ response is currently due by November 20, 2019.

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4.

On October 23, 2019, Plaintiff filed its Motion for Leave to File Documents Under

Seal [ECF 168]. Defendants’ response is currently due by November 20, 2019.
5.

The Parties have conferred and agree to allow the Plaintiff up to and including

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December 6, 2019 to file their Opposition to Defendants’ Motion to Dismiss, in Part, Plaintiff’s

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Complaint [ECF 166]. The Parties further agree to allow Defendants up to and including December

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11, 2019 to file both their Opposition to Plaintiff’s Motion to Compel Defendants to Produce

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Electronic Discovery and for Sanctions and Incorporated Memorandum of Law and their

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Opposition to Plaintiff’s Motion for Leave to File Documents Under Seal.

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6.

The Parties have conferred and respectfully request this Court continue the hearing

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on motions [ECF 145], [ECF 153], [ECF 157], [ECF 167], and [ECF 168] until the week of

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January 6-10, 2020, or anytime thereafter at the Court’s convenience.

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Case 2:15-cv-01412-JAD-DJA Document 174 Filed 11/12/19 Page 3 of 4

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7.

this is the first request for an extension of time to hearing the motions pending before this Court.

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This is the second stipulation for an extension of time to file said documents; and

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This extension is sought in good faith, and is not intended for purposes of delay nor

prejudice towards any party.
WHEREFORE, the Parties respectfully request that the Court enter this order extending:

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Plaintiff’s deadline to file their Opposition to Defendants’ Motion to Dismiss, in Part, Plaintiff’s

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Complaint [ECF 166] from November 15, 2019 to December 6, 2019; Defendants’ deadline to

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file their Opposition to Plaintiff’s Motion to Compel Defendants to Produce Electronic Discovery

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and for Sanctions and Incorporated Memorandum of Law [ECF 167] from November 20, 2019 to

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THE WRIGHT LAW GROUP P.C.
2340 Paseo Del Prado, Suite D-305
Las Vegas, Nevada 89102
Tel: [phone] Fax: [phone]

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December 11, 2019; Defendant’s Opposition to Plaintiff’s Motion for Leave to File Documents

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Under Seal [ECF 168] from November 20, 2019 to December 11, 2019; Hearing on motions [ECF

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145], [ECF 153], [ECF 157], [ECF 167], and [ECF 168] from November 25, 2019 to January ___,
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1:00 p.m.
2020 at ___:___ AM/PM in LV Courtroom 3C; and provide such other relief as is just and
3A

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proper.

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Case 2:15-cv-01412-JAD-DJA Document 174 Filed 11/12/19 Page 4 of 4

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Respectfully submitted this 12th day of November, 2019.

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THE WRIGHT LAW GROUP P.C.
2340 Paseo Del Prado, Suite D-305
Las Vegas, Nevada 89102
Tel: [phone] Fax: [phone]

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SNELL & WILMER, LLP

THE WRIGHT LAW GROUP, P.C.

/s/ Richard C. Gordon
RICHARD C. GORDON, ESQ.
Nevada Bar No. 9036
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
Phone: [phone]
Facsimile: [phone]
Attorneys for Plaintiffs

/s/ Amy J. Smith
AMY J. SMITH, ESQ.
Nevada Bar No. 14954
2340 Paseo Deal Prado, Suite D-305
Las Vegas, Nevada 89102
Phone: [phone]
Facsimile: [phone]
Attorneys for Defendants
AMIR QURESHI a/k/a AMIER QURESHI,
a/k/a AMIER I. QURESHI, a/k/a AMIER F.
QURESHI, SR.; ASIM QURESHI a/k/a
ALEX QURESHI, a/k/a AZIM QURESHI
a/k/a AZIM DeDREAM, and SEHER
QURESHI

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE

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DATED:

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November 14, 2019