LHF Productions, Inc. v. Does

Filing 128

ORDER Granting 125 Stipulation to Extend Time Re: 120 Motion to Dismiss. Responses due by 3/12/2018. Signed by Judge Jennifer A. Dorsey on 2/21/2018. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:16-cv-02028-JAD-NJK Document 125 Filed 02/14/18 Page 1 of 3

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CHARLES C. RAINEY,ESQ.
Nevada Bar No. 10723
[e-mail]
HAMRICK & EVANS LLP
7670 W. Lake Mead Blvd., Ste. 140
Las Vegas, Nevada 89128
+1.702.425.5100(ph)
+1.818.763.2308 (fax)
Attorneyfor Plaintiff
LHF Productions, Inc.,
a Nevada Corporation

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

HAMRICK & EVANS, LLP

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LHF PRODUCTIONS,INC., a Nevada
Corporation,

Case No.: 2:16-cv-02028-JAD-NJK

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Plaintiff,

STIPULATION AND ORDER TO EXTEND
DEFENDANT'S DEADLINE TO RESPOND
TO THE PLAINTIFF'S MOTION TO
DISMISS

vs.
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BRIAN KABALA,an individual.
Defendants.

[
SECOND REQUEST]

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A nd related counter-claims

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COMES NOW Plaintiff LHF PRODUCTIONS, INC. ("Plaintiff') and Defendant

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BRIAN KABALA ("Defendant"), by and through their respective counsel of record, and hereby

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stipulate and agree to extend the time by which the Defendant must respond to the Plaintiff's

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pending Motion to Dismiss the Defendant's Amended Counter-Claims, filed on February 9, 2018

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[
ECF No. 120](the "Motion to Dismiss"), agreeing as follows:

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-ISTIPULATION TO EXTEND DEADLINE TO RESPOND TO MOTION TO DISMISS

Case 2:16-cv-02028-JAD-NJK Document 125 Filed 02/14/18 Page 2 of 3

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PROCEDURAL BACKGROUND

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1.

On February 9, 2018, Plaintiff filed its Motion to Dismiss. Per the Court's

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February 21, 2018 Minute Order (ECF No. 121), Defendant's response is due by February 26,

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2018.

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2.

The Plaintiff and Defendant now hereby stipulate to extend the deadline for the

Defendant to respond to the Motion to Dismiss to Monday, March 12, 2018.
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This is the Second Request for an extension of this deadline; the parties

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submitted a stipulation yesterday with an identical request (ECF No. 122); however, the Court

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denied the request without prejudice, because it had been submitted concurrently in the same

HAMRICK & EVANS, LLP

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f
iling as a request to extend another briefing deadline.
4.

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This request is made in good faith and not made for the purpose of undue delay.
GOOD CAUSE STATEMENTS

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Defendant seeks additional time to respond to the Motion to Dismiss, noting that

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Defendant's lead counsel, Lisa Clay, Esq., was on a pre-planned vacation out of the country at

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the time of the filing of the Motion to Dismiss and will not return until February 15, 2018.

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Based on Counsel will need additional time to review the Motion to Dismiss and craft an

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Opposition.

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-2STIPULATION TO EXTEND DEADLINE TO RESPOND TO MOTION TO DISMISS

Case 2:16-cv-02028-JAD-NJK Document 125 Filed 02/14/18 Page 3 of 3

WHEREFORE, subject to the Court's approval below, Plaintiff LHF PRODUCTIONS,
INC. and Defendant BRIAN KABALA hereby stipulate and agree to extend the deadline for the
Defendant to respond to the Motion to Dismiss from Monday, February 26, 2018 to Monday,
March 12, 2018, and Plaintiffs deadline to file its Reply brief be similarly extended.
Respectfully submitted February 14, 2018

HAMRICK & EVANS, LLP

HAMRICK & EVANS LLP
/s/ Charles C. Rainey
CHARLES C. RAINEY, ESQ.
Nevada Bar No. 10723
[e-mail]
7670 W. Lake Mead Blvd., Ste. 140
Las Vegas, Nevada 89128
+1.702.425.5100(ph)
Attorneyfor Plaintiff
LHF Productions, Inc.

SAR & LATHAM

J
AN D. BLUM,ESQ.
N Vada Bar No. 9515
[e-mail]
4Q S. Rampart Blvd., Ste. 400
L s Vegas, Nevada 89145
+1.702.362.7800(ph)
Attorneyfor Defendant,
Brian Kabala
ORDER

Based on the parties' stipulation [ECF No. 125] and good cause appearing, IT IS HEREBY
ORDERED that the deadline for the Defendant to respond to the Plaintiffs pending Motion to
Dismiss is hereby extended to Monday, March 12, 2018, and Plaintiffs deadline to file its Reply
brief is hereby similarly extended.
IT IS SO ORDERED.

February 21, 2018.
Dated: Las Vegas, Nevada

UNITED
MAGISTRATE JUDGE
UNITED STATES DISTRICT JUDGE

-3STIPULATION TO EXTEND DEADLINE TO RESPOND TO MOTION TO DISMISS