Perez v. Wellfleet Communications

Filing 70

ORDER Granting 69 Stipulation to Extend Time. Lighthouse Communications, LLC, New Choice Communications, Inc. and Ryan Roach answer due 11/6/2017. Signed by Magistrate Judge George Foley, Jr on 10/31/17. (Copies have been distributed pursuant to the NEF - ADR)

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Case 2:16-cv-02353-GMN-GWF Document 69 Filed 10/30/17 Page 1 of 2 1 2 3 4 5 6 7 8 GARG GOLDEN LAW FIRM ANTHONY B. GOLDEN, ESQ. Nevada Bar No. 9563 PUNEET K. GARG, ESQ. Nevada Bar No. 9811 3185 St. Rose Parkway, Suite 325 Henderson, Nevada 89052 Tel: (702) 850-0202 Fax: (702) 850-0204 Email: pgarg@garggolden.com Email: agolden@garggolden.com Counsel for Defendants Ryan Roach, New Choice Communications, Inc., and Lighthouse Communications, LLC 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 12 13 R. ALEXANDER ACOSTA, Secretary of Labor, United States Department of Labor, CASE NO.: Plaintiff, 14 STIPULATION AND [PROPOSED] ORDER TO EXTEND DEADLINE TO RESPOND TO FIRST AMENDED COMPLAINT 15 v. 16 WELLFLEET COMMUNICATIONS, LLC, a Nevada Limited Liability Company; NEW CHOICE COMMUNICATIONS, INC., a Nevada Corporation; LIGHTHOUSE COMMUNICATIONS, LLC, a Nevada Limited Liability Company; ALLEN ROACH, an individual; RYAN ROACH, aka RYAN LORE, an individual, 17 18 19 2:16-cv-02353-GMN-GWF (First Request) 20 Defendants. 21 22 Plaintiff, R. Alexander Acosta, Secretary of Labor, United States Department of Labor, by 23 and through the Secretary’s counsel of record, and Defendants, New Choice Communications, 24 Inc., (“New Choice”), Lighthouse Communications, LLC (“Lighthouse”), and Ryan Roach 25 (“Ryan”) (collectively, “Defendants”), by and through their counsel of record, the Garg Golden 26 Law Firm, hereby stipulate to extend the deadline for Defendants to answer or otherwise respond 27 to Plaintiff’s First Amended Complaint (“FAC”) (ECF No. 44) to November 6, 2017 and for 28 Plaintiff to respond by December 8, 2017 to any motion Defendants might file in response to the GARG GOLDEN LAW FIRM 3185 St. Rose Parkway Suite 325 Henderson, Nevada 89052 (702) 850-0202 1 of 2 Case 2:16-cv-02353-GMN-GWF Document 69 Filed 10/30/17 Page 2 of 2 1 FAC. 2 Counsel for Defendants had an unexpected death in the family and had to go out of town 3 last minute for a funeral and was therefore unable to complete the responsive pleading to the FAC. 4 Additionally, the parties were in several depositions in this case pursuant to the stipulated 5 discovery extension, which required Defendants’ counsel’s attendance despite not having appeared 6 in the case yet. This is the first request for an extension of this deadline, it is not made for the 7 purposes of delay, and the parties submit that good cause appears for the extension. The extension 8 will allow Defendants’ counsel sufficient time to complete the responsive pleading to the FAC and 9 for Plaintiff’s counsel to respond, if necessary. 10 Dated this 30th day of October, 2017 Dated this 30th day of October, 2017 11 GARG GOLDEN LAW FIRM U.S. DEPARTMENT OF LABOR By /s/ Anthony B. Golden ANTHONY B. GOLDEN, ESQ. 3185 St. Rose Parkway, Suite 325 Henderson, Nevada 89052 (702) 850-0202 Counsel for Defendants Ryan Roach, New Choice Communications, Inc., and Lighthouse Communications, LLC By /s/ Tara Stearns LARA BREMER, ESQ. TARA STEARNS, ESQ. DAVID EDELI, ESQ. Trial Attorneys Counsel for Plaintiff Secretary of Labor 12 13 14 15 16 17 18 ORDER IT IS SO ORDERED 19 20 21 UNITED STATES DISTRICT JUDGE U.S. MAGISTRATE JUDGE UNITED STATES MAGISTRATE JUDGE 22 23 DATED: October 31, 2017 24 25 26 27 28 GARG GOLDEN LAW FIRM 3185 St. Rose Parkway Suite 325 Henderson, Nevada 89052 (702) 850-0202 2 of 2

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