Rosen Materials of Nevada, LLC v. The MDA, LLC et al

Filing 11

ORDER granting 10 Motion for Permission to Attend 7/5/2017 Hearing Telephonically. The call-in telephone number is [phone], access code: 3912597 Signed by Magistrate Judge Cam Ferenbach on 6/29/2017. (Copies have been distributed pursuant to the NEF - JM)

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Michael D. Stanger, Esq.
Nevada Bar No. 8272
STRONG & HANNI
102 South 200 East, Suite 800
Salt Lake City, UT 84111
Telephone: [phone]
Facsimile: [phone]
Email : [e-mail]

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Chet A. Glover, Esq.
Nevada Bar No. 10054
SMITH LARSEN & WIXOM
Hills Center Business Park
1935 Village Center Circle
Las Vegas, Nevada 89134
Tel: [phone]
Fax: [phone]
Email: [e-mail]

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Attorneys for Defendants, The MDA, LLC,
Santa Fe Acoustics, LLC and Duaine Salazar

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IN THE UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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ROSEN MATERIALS OF NEVADA, LLC, a
Nevada Limited Liability Company,

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Plaintiff,

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vs.

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THE MDA, LLC, a Utah Limited Liability
Company; SANTA FE ACOUSTICS, LLC,
an Arizona Limited Liability Company;
DUAINE SALAZAR, an individual; ROE
CORPORATIONS 1 through 20, inclusive;
and DOES 1 through 20, inclusive,

MOTION FOR PERMISSION TO
ATTEND HEARING
TELEPHONICALLY

Case No. 2:17-cv-01687-JAD-VCF
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Defendants.

Judge Jennifer A. Dorsey

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Defendants The MDA, LLC; Santa Fe Acoustics, LLC; and Duaine Salazar (the

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Defendants), by and through counsel, hereby move for permission to attend upcoming hearing

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telephonically.
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1.

Defendants removed this case to federal court on June 16, 2017.

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By virtue of FED. R. CIV. P. 81(c)(2)(C), Defendants’ deadline to respond to the

Complaint was 7 days after filing the notice of removal.
3.

Although Defendants made a good faith request that Plaintiff stipulate to a 14-

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day extension, Plaintiff has declined to stipulate to the requested extension.
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4.

Defendants then moved this court for a 14-day extension pursuant to FED. R. CIV.

P. 7, LR 7-2, and LR IA 6-1.
5.

On June 27, 2017, this court ordered that the Motion for Extension of Time to

Answer or Otherwise Respond to Complaint be heard at 10:00 AM, July 5, 2017.

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6.

Defendants’ local Nevada co-counsel, Chet Glover, is unavailable to attend the

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July 5, 2017 hearing.
7.

Defendants’ co-counsel, Michael Stanger, a Nevada licensed attorney, is located

in Utah.
8.

Considering the anticipated short length of time necessary to argue this Motion,

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the added complications of following a long holiday weekend, and the high costs associated with
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travel to Nevada, Defendants respectfully request that Defendants’ counsel, Michael Stanger, be
permitted to attend the July 5, 2017 hearing by telephone.
9.

LR 1-1(b) specifically encourages parties to litigation to reduce costs by

appearing before magistrate judges via telephone.

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WHEREFORE, for all the foregoing reasons, Defendants respectfully request that the
Court allow Defendants’ counsel to attend the July 5, 2017 hearing telephonically.
DATED this 29th day of June, 2017.

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STRONG & HANNI, PC

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/s/ Michael D. Stanger
Michael D. Stanger
Co-counsel for Defendants, The MDA, LLC,
Santa Fe Acoustics, LLC and Duaine Salazar

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The call-in telephone number is [phone], access code: 3912597. The call
must be made five minutes prior to the hearing time. The court will join the call and
convene the proceedings. The call must be made on a land line. The use of a cell
phone or speaker phone during the proceedings is prohibited.

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6-29-2017

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CERTIFICATE OF SERVICE

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I hereby certify that on the 29th day of June, 2017, a true and correct copy of the

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Foregoing MOTION FOR PERMISSION TO ATTEND HEARING TELEPHONICALLY

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was served by the method indicated

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below to the following:
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Chet A. Glover, Esq.
SMITH LARSEN & WIXOM
1935 Village Center Circle
Las Vegas, NV 89134

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(X)
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U.S. Mail, Postage Prepaid
Hand Delivered
Electronic E-File
Facsimile

Becky A. Pintar, Esq.
Bryan L. Albison, Esq.
PINTAR ALBISTON LLP
6053 S. Fort Apache Road, #120
Las Vegas, NV 89148

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(X)
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U.S. Mail, Postage Prepaid
Hand Delivered
Electronic E-File
Facsimile

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/s/ Adriana Garcia
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