Wingen et al v. Ventrum Energy Corp. et al

Filing 161

ORDER Granting 160 Motion to Extend Time. Proposed Joint Pretrial Order due by 1/3/2019. Signed by Magistrate Judge Cam Ferenbach on 11/27/2018. (Copies have been distributed pursuant to the NEF - ADR)

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STELLAR PACIFIC BUSINESS LAW PLLC
Fara Daun
Pro Hac Vice
[e-mail]
9505 19th Ave. SE, Ste. 109
Everett, WA 98208
Tel: [phone]
GARMAN TURNER GORDON LLP
DYLAN T. CICILIANO
Nevada Bar No. 12348
Email: [e-mail]
650 White Drive, Suite 100
Las Vegas, NV 89119
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiffs Philip and Karen Wingen

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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PHILIP WINGEN, et al.
Case No. 2:15-cv-02043-JCM-(VCF)
Plaintiffs,

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v.

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VENTRUM ENERGY CORP., et al.

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JOINT REQUEST FOR EXTENSION OF
TIME TO FILE THE JOINT PRE-TRIAL
ORDER
(First Request)
AND ORDER

Defendants.

JOINT REQUEST FOR EXTENION OF TIME TO FILE JOINT PRE-TRIAL ORDER
(First Request)
WHEREAS the Discovery Plan and Scheduling Order in this matter (ECF No. 134)

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requires the parties to file a Joint Pretrial Order within “30 days after the decision of the
dispositive motions or until further order of the Court” (Id. at 2:2-3); and

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WHEREAS Defendants Fossil Energy, Inc.; West Salt Creek, Inc.; Montgomery George,
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Paul Grady, William Sturdevant, and Tari Vickery (“Fossil Defendants”) by and through their

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attorney Nikola Skrinjaric, Esq., filed a Motion for Summary Judgment on May 2, 2018, which
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Plaintiffs opposed and to which Opposition the Fossil Defendants Replied on June 7, 2018; and

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WHEREAS the Court entered its decision in the Fossil Defendants’ Motion for Summary

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Judgment on November 16, 2018; making the due date for the Joint Pretrial Order December 17,

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2018;

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WHEREAS, Counsel for the Fossil Defendants, Nikola Skinjaric is unavailable and will

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be out of the country until December 10. 2018 which plans were made before the filing of the

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Court’s decision on November 16, 2018; and

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WHEREAS, Counsel pro hac vice for the Plaintiffs is getting married December 9, 2018

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and will be unavailable the week of December 10-14, 2018 and the plans for the wedding were

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set before the filing of the Court’s decision on November 16, 2018; and
WHEREAS, all other parties have either been dismissed or are subject to a clerk’s default

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and no other party will be participating in crafting the Joint Pretrial Order;

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NOW THEREFORE, Plaintiffs and the Fossil Defendants, by and through their counsels,

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jointly request that the Court extend the deadline for filing the Joint Pretrial Order until January3,

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2019.

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Dated this 26th day of November, 2018.
/s/ Fara Daun
STELLAR PACIFIC BUSINESS LAW
PLLC
Fara Daun, Pro Hac Vice
9505 19th Ave. SE, Suite 109
Everett, WA 98208
Tel: [phone]
Email: [e-mail]

/s/ Nikola Skrinjaric
Nevada Bar No. 3605
8430 W. Lake Mead Blvd., Ste. 100
Las Vegas, Nevada 89128
Tel: [phone]
Fax: [phone]
[e-mail]
Attorney for Defendants, Paul Grady,
Montgomery George, Fossil Energy, Inc.,
West Salt Creek, Inc., William Sturdevant,
and Tari Vickery

Dylan T. Ciciliano
GARMAN TURNER GORDON LLP
Nevada Bar No. 12348
Email: [e-mail]
650 White Drive, Suite 100
Las Vegas, NV 89119
Tel: [phone]
Fax: [phone]

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Attorneys for Plaintiffs Phillip and Karen
Wingen

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ORDER

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It is hereby ordered that the time for the Parties to file the Joint Pre-Trial Order shall be

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extended up to and including January 3, 2019.

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Dated this 27th day of November, 2018.

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UNITED STATES MAGISTRATE JUDGE

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CERTIFICATE OF SERVICE

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I certify on this 26rd day of November, 2018, I caused a copy of this Joint Request For Extension

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Of Time To File Joint Pretrial Order and Order to be served via ECF on all counsel of record.

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I HEREBY DECLARE THAT THE ABOVE STATEMENT IS TRUE TO THE

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BEST OF MY KNOWLEDGE AND BELIEF, AND THAT I UNDERSTAND IT IS

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MADE FOR USE AS EVIDENCE IN COURT AND IS SUBJECT TO PENALTY FOR

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PERJURY.

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Executed this 26th day of November, 2018, in Lynnwood, Washington.
STELLAR PACIFIC BUSINESS LAW PLLC

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By /s/ Fara Daun
Fara Daun, Pro Hac Vice
Email: [e-mail]
202 164th St. SW, # 215
Lynnwood, WA 98087
Tel: [phone]
Of Attorneys for Plaintiffs Phillip and Karen
Wingen

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