The Hackett Miller Company, Inc. v. GFour Productions, LLC et al

Filing 25

ORDER Granting 24 Stipulation re 22 MOTION to Dismiss for (1) Lack of Personal Jurisdiction, (2) Failure to Join a Necessary Party, and (3) Improper Venue, and (4) Request to Transfer Venue re 1 Complaint.( Responses due by 10/17/2016.) IT IS FURTHER ORDERED that 23 Stipulation is MOOT. Signed by Judge Richard F. Boulware, II on 10/10/16. (Copies have been distributed pursuant to the NEF - ADR)

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Ryan Gile, Esq.
Nevada Bar No. 8807
[e-mail]
F. Christopher Austin, Esq.
Nevada Bar No. 6559
[e-mail]
WEIDE & MILLER, LTD.
7251 W. Lake Mead Blvd., Suite 530
Las Vegas, NV 89128-8373
Tel: [phone]
Fax: [phone]

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Attorneys for Plaintiff The Hackett Miller Company, Inc.
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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THE HACKETT MILLER COMPANY, INC., a
Nevada corporation,

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Plaintiff,
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v.
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GFOUR PRODUCTIONS, LLC, a Florida limited
liability company; and SPOTLIGHT RIGHTS,
LLC, a Florida limited liability company,

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Defendants.

Case No.: 2:16-cv-00418-RFB-NJK
STIPULATION AND (PROPOSED)
ORDER FOR EXTENSION OF TIME
FOR PLAINTIFF TO FILE AN
OPPOSITION TO DEFENDANTS’
MOTION TO DISMISS FOR:
(1) LACK OF PERSONAL
JURISDICTION, (2) FAILURE TO
JOIN A NECESSARY PARTY,
(3) IMPROPER VENUE, AND
(4) REQUEST TO TRANSFER VENUE

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(Second Request)
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Plaintiff THE HACKETT MILLER COMPANY, INC. and Defendants GFOUR

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PRODUCTIONS, LLC and SPOTLIGHT RIGHTS LLC, by and through their undersigned

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counsel, hereby stipulate and agree to an 15-day extension of time up to and including September

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30, 2016, for Plaintiff to file an Opposition to Defendants’ Motion to Dismiss for: (1) Lack of

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Personal Jurisdiction, (2) Failure to Join a Necessary Party, (3) Improper Venue, and (4) Request

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to Transfer Venue in the above-captioned matter (ECF No. 22) (“Motion to Dismiss”).

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Defendant’s Motion to Dismiss was filed on August 29, 2016. On September 13, 2016,

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the parties filed a Stipulation giving Plaintiff a 15-day extension of time to file an Opposition to

W EIDE & MILLER, LTD.
7251 W. LAKE MEAD BLVD.,
SUITE 530
LAS VEGAS,
NEVADA 89128
[phone]

RRG-w-4102

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Stipulation and Order to Extend Time (2nd Request)

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Defendants’ Motion to Dismiss (ECF No. 23) (the “First Extension Request”) which extended the

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original deadline for Plaintiff’s Opposition to Defendants’ Motion to Dismiss to September 30,

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2016. The Court has not yet signed the First Extension Request.

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By and through this Stipulation, the parties agree to extend the deadline for Plaintiff to file

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Plaintiff’s Opposition to Defendants’ Motion to Dismiss to October 17, 2016. This is Plaintiff’s

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second request for an extension of time for Plaintiff to file an Opposition to Defendants’ Motion

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to Dismiss. Plaintiff requests an extension of time to file an Opposition to Defendants’ Motion

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to Dismiss in order to avoid unfairly prejudicing Plaintiff in this matter. Plaintiff’s counsel is

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presently scheduled to appear for a jury trial commencing October 3rd and continuing through

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October 7, 2016. Given the necessity of devoting full attention to the trial and final preparations

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for the same, absent the brief extension requested, Plaintiff’s counsel will be unable to

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competently and fully address the complex jurisdictional and venue issues raised in Defendants’

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Motion to Dismiss, thus unfairly prejudicing Plaintiff in this matter. Defendants, through this

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stipulation, have agreed to Plaintiff’s requested extension under the circumstances.

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W EIDE & MILLER, LTD.
7251 W. LAKE MEAD BLVD.,
SUITE 530
LAS VEGAS,
NEVADA 89128
[phone]

RRG-w-4102

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Stipulation and Order to Extend Time (2nd Request)

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For these reasons, this Request is made for good cause and not for purposes of delay.

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Dated: September 28, 2016

Dated: September 28, 2016

Respectfully Submitted,

Respectfully Submitted,

/s/ Ryan Gile
Ryan Gile (NV Bar No. 8807)
[e-mail]
F. Christopher Austin (NV Bar No. 6559)
[e-mail]
WEIDE & MILLER. LTD.
7251 W. Lake Mead Blvd., Suite 530
Las Vegas, NV 89128
Tel: [phone]
Fax: [phone]

/s/ Jonathan Winter
Gene S. Winter (pro hac vice)
gwinter @ssjr.com
Jonathan A. Winter (pro hac vice)
[e-mail]
ST. ONGE STEWARD JOHNSTON AND
REENS LLC
986 Bedford Street
Stamford, CT 06905-5619
Tel: [phone]
Fax: [phone]

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Attorneys for Plaintiff, The Hackett
Miller Company, Inc.

Ronald D. Green (NV Bar No. 7360)
Alex J. Shepard (NV Bar No. 13582)
RANDAZZA LEGAL GROUP, PLLC
4035 S. El Capitan Way
Las Vegas, NV 89147
Tel: [phone]
Fax: [phone]
[e-mail]

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Attorneys for Defendants, GFour Productions,
LLC and Spotlight Rights, LLC

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IT IS SO ORDERED.

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UNITED STATES MAGISTRATE JUDGE
__________________________
RICHARD F. BOULWARE, II
Dated:
United States District Judge

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DK #23 - MOOT.

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DATED this 10th day of October, 2016.

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W EIDE & MILLER, LTD.
7251 W. LAKE MEAD BLVD.,
SUITE 530
LAS VEGAS,
NEVADA 89128
[phone]

RRG-w-4102

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Stipulation and Order to Extend Time (2nd Request)

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CERTIFICATE OF SERVICE

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I hereby certify that I am an employee of Weide & Miller, Ltd. and that on September 28,

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2016, I electronically filed the foregoing document with the Clerk of the Court using CM/ECF. I

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further certify that a true and correct copy of the foregoing document will be served via

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transmission of Notices of Electronic Filing generated by CM/ECF.

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/s/ James L. Morris
An employee of WEIDE & MILLER, LTD.

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W EIDE & MILLER, LTD.
7251 W. LAKE MEAD BLVD.,
SUITE 530
LAS VEGAS,
NEVADA 89128
[phone]

RRG-w-4102

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Stipulation and Order to Extend Time (2nd Request)