VanDeHey v. Real Social Dynamics, Inc. et al

Filing 127

ORDER Granting 126 Stipulation to Extend Deadline for the Parties to Comply with May 3, 2024 Order (ECF No. 123). See order for details. Signed by Magistrate Judge Nancy J. Koppe on 5/10/2024. (Copies have been distributed pursuant to the NEF - ALZ)

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George F. Ogilvie III (NV Bar #3552)
Amanda C. Yen, Esq. (NSBN #9726)
MCDONALD CARANO LLP
2300 W. Sahara Ave, Suite 1200
Las Vegas, NV 89102
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Steven L. Procaccini (Admitted Pro Hac Vice)
PROCACCINI LAW GROUP, LLC
100 Enterprise Drive, Suite 301
Rockaway, New Jersey 07866
Telephone: [phone]
Fax: [phone]
[e-mail]
Attorneys for Plaintiff Todd VanDeHey

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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TODD VANDEHEY, an individual,

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Plaintiff,

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vs.

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REAL SOCIAL DYNAMICS, INC., a Nevada
corporation; NICHOLAS KHO, an individual;
OWEN COOK, an individual; AMBER KHO, an
individual, John Does 2 through 10, all whose true
names are unknown; ABC Companies 1 through
10, all whose true names are unknown,

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Defendants.
REAL SOCIAL DYNAMICS, INC., a Nevada
corporation; NICHOLAS KHO, an individual;
OWEN COOK, an individual; AMBER KHO, an
individual,
and

Counterclaimants,

VALENTINE LIFE, a Nevada corporation,

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Nominal Counterclaimant,

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vs.

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TODD VANDEHEY, an individual,

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Counter-defendant.

Case No.: 2:17-cv-02230-JAD-NJK
STIPULATION AND ORDER TO
EXTEND DEADLINE FOR THE
PARTIES TO COMPLY WITH
MAY 3, 2024 ORDER (ECF No. 123)
(First Request)

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Plaintiff Todd VanDeHey, Counterdefendants Valentine Life and Todd VanDeHey, and

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Defendants/Counterclaimants Real Social Dynamics, Inc., Nicholas Kho, Owen Cook and Amber

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Kho hereby stipulate and agree to the following:

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1) On June 29, 2018, the Court entered an Order (ECF No. 91) granting in part

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Defendants/Counterclaimants’ motion to compel arbitration, denying Plaintiff’s motion

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for summary judgment as moot and staying the case;

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2) This matter remained stayed from June 29, 2018 through March 26, 2024, at which time

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the Court entered an Order (ECF No. 120) granting Plaintiff’s motion to confirm the

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arbitration award, lifting the stay and directing the parties to appear for a status hearing
on April 16, 2024;

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3) At the time of the April 16, 2024 status hearing, counsel for Plaintiff/Counterdefendants

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advised the Court that Plaintiff intends to move for leave to amend the operative

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pleading to add parties and claims, and counsel for Defendants/Counterclaimants’

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advised the Court that Defendants intend to file a dispositive motion;

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4) Counsel for Plaintiff/Counterdefendants represents that the motion for leave to amend

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the operative pleading was in progress at the time the Court entered the Order (ECF No.

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123) on May 6, 2024 directing the parties to file a stipulation by May 10, 2024

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identifying the claims and parties remaining in the case, identifying the discovery

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completed to date, identifying the discovery remaining to be completed and proposing

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a schedule for advancing the case;

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5) Counsel for Plaintiff/Counterdefendants represents that court appearances and client

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obligations in other matters on May 7-10 render it very difficult to comply with the May

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10, 2024 deadline; therefore, counsel for Plaintiff/Counterdefendants contacted counsel

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for Defendants/Counterclaimants to stipulate to a request for a two-week extension;

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...

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...

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...

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Page 2 of 4

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6) This is the first request to extend the deadline to comply with the May 3, 2024 Order
(ECF No. 123); and
7) The undersigned represent that this stipulation is not designed for purposes of delay.

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DATED this 9th day of May, 2024.
McDONALD CARANO LLP

MAIER GUTIERREZ & ASSOCIATES

By: /s/ George F. Ogilvie III
George F. Ogilvie III (NSBN 3552)
Amanda C. Yen, Esq. (NSBN 9726)
2300 W. Sahara Avenue, Suite 1200
Las Vegas, NV 89102
Telephone: [phone]
Fax: [phone]
[e-mail]
[e-mail]

By: /s/ Joseph A. Gutierrez
Joseph A. Gutierrez, Esq. (NSBN 9046)
8816 Spanish Ridge Avenue
Las Vegas, Nevada 89148
Telephone: [phone]
[e-mail]
Attorneys for REAL SOCIAL
DYNAMICS, INC., NICHOLAS KHO,
OWEN COOK, and AMBER KHO

Steven L. Procaccini
(Admitted Pro Hac Vice)
PROCACCINI LAW GROUP, LLC
100 Enterprise Drive, Suite 301
Rockaway, New Jersey 07866
Telephone: [phone]
[e-mail]
Attorneys for TODD VANDEHEY and
VALENTINE LIFE

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NO FURTHER EXTENSIONS
WILL BE GRANTED.

IT IS SO ORDERED.

UNITED STATES MAGISTRATE JUDGE

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DATED:

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Page 3 of 4

May
10, 2024
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