LHF Productions, Inc. v. Does

Filing 177

ORDER Granting 176 Stipulation to Extend Time Re: 174 , 175 Motions to Dismiss. Responses due by 9/6/2018. Replies due by 9/17/2018. Signed by Judge Jennifer A. Dorsey on 8/21/2018. (Copies have been distributed pursuant to the NEF - ADR)

JONATHAN D.BLUM,ESQ.
Nevada Bar No. 009515
ERIC D. WALTHER,ESQ.
Nevada Bar No. 13611
KOLESAR & LEATHAM
400 South Rampart Boulevard, Suite 400
Las Vegas, Nevada 89145
Telephone: [phone]
Facsimile: [phone]
E-Mail: [e-mail]
[e-mail]
LISA L. CLAY,ESQ. - Pro Hac Vice (Illinois Bar No. 6277257)
345 North Canal Street Suite C202
Chicago, Illinois 60606-1333
Telephone: [phone]
Email:
[e-mail]
-andJOSEPH CURTIS EDMONDSON,ESQ. - Pro Hac Vice (California Bar No. 236105)
EDMONDSON IP LAW,LAW OFFICES OF J. CURTIS EDMONDSON,PLLC
3699 NE John Olsen Ave.
Hillsboro, Oregon 97124
Telephone: [phone]
Email
[e-mail]
Attorneysfor Defendant/Counter-Plaintiff
Brian Kabala
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
** *
LHF PRODUCTIONS,INC., a Nevada
Corporation,
Plaintiff,

CASE NO. 2:16-cv-02028-JAD-NJK

vs.

AGUSTIN BERTOLIN,an individual; MARIA
GONZALEZ,an individual; BRIAN KABALA,
an individual; JOHN KOEHLY,an individual;
DANIEL O'CONNELL, an individual;
DONALD PLAIN,an individual; DAVID
POOR,an individual; ANTE SODA,an
individual; MATTHEW STEWART,an
individual; AARON TAKAHASHI,an
individual; and JOHN AND JANE DOES, 1-10,

STIPULATION AND ORDER TO
EXTEND BRIEFING DEADLINES
ON PLAINTIFF LHF
PRODUCITONS,INC.'s MOTION
TO VOLUNTARILY DISMISS WITH
PREJUDICE ITS CLAIMS AGAINST
BRIAN KABALA [ECF No. 174] AND
MOTION TO DISMISS
DEFENDANT BRIAN KABALA'S
DECLARATORY JUDGMENT
COUNTERCLAIM FOR LACK OF
SUBJECT MATTER JURISDICTION
[ECF No. 175]

Defendants.
BRIAN KABALA,an individual,

[FIRST REQUEST]

Counter-Plaintiff,
vs.

[ECF No. 176]

LHF PRODUCTIONS,INC., a Nevada
Corporation,
Counter-Defendant.
2955374_2 (10254-1)

Page 1 of4

STIPULATION AND ORDER TO EXTEND BRIEFING DEADLINES ON PLAINTIFF
LHF PRODUCITONS,INC.'s MOTION TO VOLUNTARILY DISMISS WITH
PREJUDICE ITS CLAIMS AGAINST BRIAN KABALA [ECF No. 174] AND MOTION
TO DISMISS DEFENDANT BRIAN KABALA'S DECLARATORY JUDGMENT
COUNTERCLAIM FOR LACK OF SUBJECT MATTER JURISDICTION [ECF No. 175]
[FIRST REQUEST]
COMES NOW Plaintiff LHF PRODUCTIONS, INC.("LHF" or "Counter-Defendant")
and Defendant BRIAN KABALA ("Kabala" or "Counter-Plaintiff'), by and through their
respective counsel of record, and hereby stipulate and agree to extend the time for Kabala to file
responses to LHF's Motion to Voluntarily Dismiss With Prejudice its Claims Against Brian
Kabala [ECF No. 174] and LHF's Motion to Dismiss Defendant Brian Kabala's Declaratory
Judgment Counterclaim for lack of Subject Matter Jurisdiction [ECF No. 175],(the "Motions to
Dismiss"), agreeing as follows:
1.

On August 13, 2018, LHF filed the above referenced Motions to Dismiss (ECF.

Nos. 174 and 175). Per LR 7-2 Kabala's responses are due by August 27, 2018.
2
.

LHF and Kabala now hereby stipulate to extend the deadline for Kabala to

respond to the Motions to Dismiss to September 6,2018.
3
.

The deadline for LHF to file its reply briefs, if any, shall be similarly extended by

ten days, from September 7, 2018, to September 17, 2018.
4.

This is the First Request for an extension on these deadlines.

5.

This request is made for good cause, in good faith, and not made for the purpose

of undue delay. Neither party will be prejudiced by the requested extension.
GOOD CAUSE STATEMENTS
6
.

Kabala seeks additional time to respond to the Motions to Dismiss, noting that the

Motions to Dismiss were filed on August 13, 2018, the day Defendant's lead counsel, Lisa Clay,
Esq., returned to the office from vacation. Upon her return, she has been preparing for two major
depositions in this case, set to take place on August 29, 2018 and August 30, 2018. She is also in
the final stages of finalizing two time-sensitive motions in this case. Preparing for these
depositions, as well as finalizing these two motions, in addition to work in an estimated 15 other

2955374_2(10254-1)

Page 2 of4

active matters, will make it extremely difficult to adequately review and respond to these two
significant motions to dismiss without an extension.
7
.

Based on Counsel's current case load, related to both this matter and general work

load, approximately ten additional days will be needed to review and respond to the Motions to
Dismiss.
WHEREFORE, subject to the Court's approval below, Counter-Defendant LHF and
Counter-Plaintiff BRIAN KABALA hereby stipulate and agree to extend the deadline for Kabala
to respond to the Motions to Dismiss from Monday, August 27, 2018 to September 6, 2018, and
LHF's deadline to file its Reply briefs from September 7, 2018 to September 17, 2018.
Respectfully submitted August 20th 2018.
KOL

WEIDE & MILLER,LTD.
By:/s/ F. Christopher Austin, Esq.
F. CHRISTOPHER AUSTIN,ESQ.
Nevada Bar No. 6559
10655 Park Run Drive, Suite 100
Las Vegas, Nevada 89144
Attorneyfor Plaintiff LHF Productions,
Inc.

R & LEATHA

By:
,►.-"~. BLUM, ESQ.
JO
Ne a Bar No. 9515
ERI I WALTHER, ESQ.
.
Ne da Bar No. 13611
400 . Rampart Blvd., Ste. 400
Las Vegas, Nevada 89145
LISA L. CLAY, ESQ. - Pro Hac Vice
(Illinois Bar No. 6277257)
345 North Canal Street Suite C202
Chicago, Illinois 60606-1333
-andJOSEPH CURTIS EDMONDSON, ESQ. - Pro
H Vice (California Bar No. 236105)
ac
EDMONDSON IP LAW, LAW OFFICES OF
J. CURTIS EDMONDSON, PLLC
3699 NE John Olsen Ave.
Hillsboro, Oregon 97124
Attorney for Defendant, Brian Kabala

ORDER
Based on the parties' stipulation [ECF No.

176) and good cause appearing, IT IS

HEREBY ORDERED that the deadline for the Kabala to respond to the Plaintiffs pending

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Motions to Dismiss is hereby extended to September 6, 2018, and LHF's deadline to file its
Reply briefs is hereby similarly extended to September 17, 2018.
IT IS SO ORDERED.
DATED this

21

day of August

2018.

UNITED STATES DISTRICT JUDGE

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