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)
Case 2:16-cv-02353-GMN-GWF Document 69 Filed 10/30/17 Page 1 of 2
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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
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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R. ALEXANDER ACOSTA, Secretary of Labor,
United States Department of Labor,
CASE NO.:
Plaintiff,
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STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINE TO
RESPOND TO FIRST AMENDED
COMPLAINT
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v.
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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,
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2:16-cv-02353-GMN-GWF
(First Request)
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Defendants.
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Plaintiff, R. Alexander Acosta, Secretary of Labor, United States Department of Labor, by
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and through the Secretary’s counsel of record, and Defendants, New Choice Communications,
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Inc., (“New Choice”), Lighthouse Communications, LLC (“Lighthouse”), and Ryan Roach
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(“Ryan”) (collectively, “Defendants”), by and through their counsel of record, the Garg Golden
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Law Firm, hereby stipulate to extend the deadline for Defendants to answer or otherwise respond
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to Plaintiff’s First Amended Complaint (“FAC”) (ECF No. 44) to November 6, 2017 and for
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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
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Case 2:16-cv-02353-GMN-GWF Document 69 Filed 10/30/17 Page 2 of 2
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FAC.
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Counsel for Defendants had an unexpected death in the family and had to go out of town
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last minute for a funeral and was therefore unable to complete the responsive pleading to the FAC.
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Additionally, the parties were in several depositions in this case pursuant to the stipulated
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discovery extension, which required Defendants’ counsel’s attendance despite not having appeared
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in the case yet. This is the first request for an extension of this deadline, it is not made for the
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purposes of delay, and the parties submit that good cause appears for the extension. The extension
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will allow Defendants’ counsel sufficient time to complete the responsive pleading to the FAC and
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for Plaintiff’s counsel to respond, if necessary.
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Dated this 30th day of October, 2017
Dated this 30th day of October, 2017
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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
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ORDER
IT IS SO ORDERED
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UNITED STATES DISTRICT JUDGE
U.S. MAGISTRATE JUDGE
UNITED STATES MAGISTRATE JUDGE
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DATED: October 31, 2017
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GARG GOLDEN
LAW FIRM
3185 St. Rose Parkway
Suite 325
Henderson, Nevada 89052
(702) 850-0202
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