The PrivateBank and Trust Company v. Cobra Thermosolar Plants, Inc.

Filing 10

ORDER Granting 9 Stipulation to Extend Time. Cobra Thermosolar Plants, Inc. answer due 10/17/2016. Signed by Magistrate Judge Cam Ferenbach on 9/16/16. (Copies have been distributed pursuant to the NEF - ADR)

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WILLIAM J. WRAY, ESQ.
Nevada Bar No. 5834
E-mail:[e-mail]
DONNA DIMAGGIO, ESQ.
Nevada Bar No. 9794
E-mail:[e-mail]
HOLLEY DRIGGS, WALCH
FINE WRAY PUZEY & THOMPSON
400 South Fourth Street, Third Floor
Las Vegas, Nevada 89101
Telephone:
702/791-0308
Facsimile:
702/791-1912
Attorneys for Defendant
Cobra Thermosolar Plants, Inc.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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THE PRIVATE BANK AND TRUST
COMPANY, a Delaware corporation,

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STIPULATION AND
[PROPOSED] ORDER TO
RESPOND TO COMPLAINT

Plaintiff,

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Case No. 2:16-cv-00983-KJD-VCF

v.
COBRA THERMOSOLAR PLANTS, INC., a
Nevada corporation,

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Defendant.

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COMES NOW, Defendant, COBRA THERMOSOLAR PLANTS, INC.

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(“Defednant”), by and through its counsel of record, Williams J. Wray, Esq., and Donna

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DiMaggio, Esq., of the law firm of HOLLEY DRIGGS WALCH FINE WRAY PUZEY

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& THOMPSON, and Plaintiff, THE PRIVATE BANK AND TRUST COMPANY

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(“Plaintiff”), by and through its counsel of record, Shan Davis, Esq., of the law firm of

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DAVIS/STIBOR, (Plaintiff and Defendant are hereinafter collectively referred to as

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“Parties”) and hereby agree and stipulate as follows:

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Plaintiff filed a Complaint on May 2, 2016. The Parties initially agreed to an

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open extension for Defendant to respond to the Complaint. After a status check with the

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Court, the Parties agreed to respond to the Complaint by September 16, 2016 or file a

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stipulation requesting a further extension if settlement discussions were continuing. The

-110868-01/1765131.docx

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Parties continue to be actively engaged in settlement discussions and wish to continue

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said discussions without incurring the cost of litigation. As such, the Parties agree to

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allow Defendant a thirty (30) day extension to respond to the Complaint. Defendant shall

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have until October 17, 2016 to respond to the Complaint.

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The Parties further agree and stipulate that the requirements proscribed in
F.R.C.P. 26 and LR 26-1 be tolled.
The Parties further agree and stipulate that should the Parties fail to resolve this

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matter, Defendant shall have ten (10) days to file a response to the Complaint.

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DATED this ___ day of September, 2016

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DATED this ___ day of September, 2016

HOLLEY DRIGGS WALCH FINE
WRAY PUZEY & THOMPSON

DAVIS/STIBOR

/s/ Donna DiMaggio
________________________________
WILLIAM J. WRAY, ESQ.
Nevada Bar No. 5834
DONNA DIMAGGIO, ESQ.
Nevada Bar No. 9794
400 South Fourth Street, Third Floor
Las Vegas, Nevada 89101
Attorneys for Defendant
Cobra Thermosolar Plants, Inc.

/s/ Shan Davis
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SHAN DAVIS, ESQ.
Nevada Bar No. 9323
410 S. Rampart Blvd., Suite 390
Las Vegas, Nevada 89145
Attorneys for Plaintiff The Private
Bank and Trust

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ORDER

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IT IS SO ORDERED.

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9-16-2016
DATED: _____________

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_______________________________
U.S. MAGISTRATE

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-210868-01/1765131.docx