Chamaria et al v. Diab et al

Filing 41

ORDER Granting 37 Stipulation to Extend Time re 20 MOTION to Dismiss for Lack of Jurisdiction. ( Replies due by 9/18/2017.) Signed by Judge Jennifer A. Dorsey on 9/11/17. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:17-cv-02023-JAD-CWH Document 37 Filed 09/08/17 Page 1 of 3

1
2
3
4
5

ALEXIS BROWN LAW, CHTD.
Alexis L. Brown (No. 12338)
725 S. 8th St., Suite 200
Las Vegas, Nevada 89101
Tel: [phone]
Fax: [phone]
[e-mail]
Attorney for Plaintiffs
UNITED STATES DISTRICT COURT

6

DISTRICT OF NEVADA

7
8
9
10
11

VISHAL CHAMARIA, an individual;
VIVEK CHAMARIA, an individual; PUJA
CHAMARIA, an individual; GAURI
CHAMARIA, an individual; P & V, LLC, a
California limited liability company; CHIP
SHOP, LLC, a California limited liability
company,
Plaintiffs,

12
13
14
15
16
17
18
19
20
21

Case No.: 2:17-CV-02023-JAD-CWH

vs.
TONY M. DIAB, an individual; SHOOK,
HARDY & BACON, L.L.P., a Missouri
limited liability partnership; MATTHEW
GREGORY JONES, an individual; G & M
MANAGEMENT SERVICES, INC., a
California corporation, dba JONES REAL
ESTATE; DOES I through X, individuals;
and ROE BUSINESS ENTITIES I through X,
inclusive,
Defendants.
STIPULATION AND ORDER TO EXTEND TIME TO RESPOND TO MOTION TO
DISMISS FOR LACK OF PERSONAL JURISDICTION (DKT. 20)
(Second Request)

22

Plaintiffs VISHAL CHAMARIA, VIVEK CHAMARIA, PUJA CHARMARIA, GAURI

23

CHAMARIA, P & V, LLC, and CHIP SHOP, LLC (collectively, the “Plaintiffs”), by and through

24

their attorney of record ALEXIS L. BROWN, ESQ. of the law office of ALEXIS BROWN LAW,

25

CHTD., and Defendants MATTHEW GREGORY JONES and G & M MANAGEMENT

26

SERVICES, INC., by and through their attorney of record BRADLEY J. HOFLAND, ESQ. of

27

the law office HOFLAND & TOMSHECK, hereby enter into this Stipulation to Extend Time to

28
1

Case 2:17-cv-02023-JAD-CWH Document 37 Filed 09/08/17 Page 2 of 3

1

Respond to Motion to Dismiss for Lack of Personal Jurisdiction (Dkt. 20) (Second Request)

2

pursuant to Fed. R. Civ. P. 6 and L.R. IA 6-1 as follows:

3

WHEREAS on July 31, 2017, Mr. Diab filed Defendant Tony M. Diab’s Notice of Motion

4

and Motion to Dismiss for Lack of Personal Jurisdiction; Memorandum of Points and Authorities

5

Thereon (the “Diab Motion to Dismiss”) (Dkt. 10).

6

WHEREAS on August 8, 2017, Defendants Matthew Gregory Jones and G & M

7

Management Services, Inc. (the “Jones Defendants”) filed a Notice of Motion and Motion to

8

Dismiss Complaint Against Defendants Matthew Gregory Jones and G & M Management

9

Services, Inc. for Lack of Personal Jurisdiction (the “Jones Defendants’ Motion to Dismiss”) (Dkt.

10
11
12

20).
WHEREAS pursuant to Court order, Plaintiffs’ response to the Jones Defendants’ Motion
to Dismiss (Dkt. 20) is currently due August 30, 2017. Dkt. 31.

13

WHEREAS the Parties previously agreed that Plaintiffs’ response to the Jones

14

Defendants’ Motion to Dismiss could be submitted along with their response to the Diab Motion

15

to Dismiss due to Plaintiffs’ allegations of the interconnectedness of the jurisdiction against Mr.

16

Diab and the Jones Defendants. Dkt. 31.

17

WHEREAS the Parties also previously agreed to extend the time for Plaintiffs to respond

18

to the Diab Motion to Dismiss and Jones Defendants’ Motion to Dismiss to allow for meaningful

19

discussion of settlement of all claims. Dkt. 28, 31, 32.

20

WHEREAS, after Plaintiffs filed their Motion for an enlargement of time to respond to

21

the Jones Defendants’ Motion to Dismiss, Dkt. 35, the Parties informally agreed to extend the

22

Plaintiffs’ response deadline to September 2, 2017 and then to September 8, 2017 to allow for

23

such ongoing settlement discussions.

24
25

WHEREAS settlement discussions have unfortunately stalled since September 6, 2017,
requiring the parties to proceed with this case.

26

WHEREAS in light of the foregoing, the Parties stipulate and agree that Plaintiffs shall

27

have this second extension until September 8, 2017 to respond to the Jones Defendants’ Motion

28

to Dismiss.
2

Case 2:17-cv-02023-JAD-CWH Document 37 Filed 09/08/17 Page 3 of 3

1

WHEREAS the Parties agree to allow the Jones Defendants a one business day extension

2

of time through September 18, 2017 to file their reply in support of the Jones Defendants’ Motion

3

to Dismiss.

4

Based on the foregoing,

5

IT IS HEREBY STIPULATED that good cause exists to allow Plaintiffs until September

6

8, 2017 to respond to the Jones Defendants’ Motion to Dismiss (Dkt. 20).

7

IT IS FURTHER STIPULATED that good cause exists to allow the Jones Defendants

8

until September 18, 2017 to file a reply in support of the Jones Defendants’ Motion to Dismiss

9

(Dkt. 20).

10

DATED this 7th day of September, 2017.

11

ALEXIS BROWN LAW, CHTD.

12
13

/s/ Alexis L. Brown
By: _________________________________
Alexis L. Brown (No. 12338)

14

Attorney for Plaintiffs

15

DATED this 8th day of September, 2017.

16

HOFLAND & TOMSHECK

17

/s/ Bradley J. Hofland
By: _________________________________
Bradley J. Hofland (No. 6343)

18
19
20

IT IS SO ORDERED.
21
22
23
24

U.S. DISTRICT COURT JUDGE
DATED: 9/11/2017

25
26
27
28
3