Gould et al v. Rogers et al

Filing 13

ORDER Granting 12 Stipulation for Extension of Time re 10 Motion to Remand to State Court and 1 Petition for Removal (First Request). Responses due by 11/13/2017. William Rogers answer due 11/10/2017. Signed by Judge Andrew P. Gordon on 10/25/17. (Copies have been distributed pursuant to the NEF - MR)

Case 2:17-cv-02435-APG-NJK Document 12 Filed 10/25/17 Page 1 of 2

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Karl O. Riley, Esq.
Nevada Bar No. 12077
SNELL & WILMER L.L.P.
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, NV 89169
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorney for Defendants William Rogers and
Harbor Freight Tools USA, Inc.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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DAN GOULD, an individual, and AUDREE
GOULD, an individual,

Case No. 2:17-cv-02435-APG-NJK

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Plaintiffs,
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Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

vs.
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WILLIAM ROGERS, an individual,
HARBOR FREIGHT TOOLS USA, INC.,
a California Corporation, DOES I through
X, inclusive, and ROE CORPORATIONS I
through X, inclusive,

STIPULATION AND ORDER TO
CONTINUE RESPONSE TO
PLAINTIFFS’ COMPLAINT AND
MOTION FOR REMAND
[FIRST REQUEST]

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Defendants.
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Plaintiffs Dan and Audree Gould, and Defendants William Rogers (“Rogers”) and Harbor

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Freight Tools USA, Inc. (“Harbor Freight,” together with Rogers, “Defendants”), through their

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respective counsel, stipulate for the first time to continue Defendant Rogers’ response to

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Plaintiffs’ Complaint and Defendants’ response to Plaintiffs’ Motion for Remand, ECF No. 10, as

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follows:
WHEREAS, Plaintiffs served Defendant Rogers with the Summons and Complaint on

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October 6, 2017;
WHEREAS, Defendant Rogers’ response to Plaintiffs’ Complaint is due October 27,

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2017;
WHEREAS, Defendants’ response to Plaintiffs’ Motion for Remand is due October 30,

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2017;
WHEREAS, this request is timely;

4827-4902-2290.2

Case 2:17-cv-02435-APG-NJK Document 12 Filed 10/25/17 Page 2 of 2

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WHEREAS, the Parties agreed to provide Defendants’ additional time to respond to
Plaintiffs’ Complaint and Motion for Remand;

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WHEREAS, this request is not made for purposes of delay and is supported by good
cause;
NOW, THEREFORE, in consideration of the foregoing, and for good cause, IT IS
HEREBY STIPULATED AND AGREED, by and between the Parties as follows:

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1.

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10, 2017.

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2.

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13, 2017.

Snell & Wilmer

L.L.P.
LAW OFFICES
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, Nevada 89169
702.784.5200

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Defendant Rogers will respond to Plaintiffs’ Complaint on or before November

Defendants will respond to Plaintiffs’ Motion for Remand on or before November

IT IS SO STIPULATED.

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DATED: October 25, 2017.

DATED: October 25, 2017.

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JENNINGS & FULTON, LTD.

SNELL & WILMER L.L.P.

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By: /s/ Adam R. Fulton
JARED B. JENNINGS, ESQ.
ADAM R. FULTON, ESQ.
TOD R. DUBOW, ESQ.
2580 Sorrel Street
Las Vegas, NV 89146
Telephone: [phone]
Facsimile: [phone]

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Attorney for Defendants William Rogers
and Harbor Freight Tools USA, Inc.

Attorneys for Plaintiffs

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By:/s/ Karl O. Riley
Karl O. Riley, Esq.
Nevada Bar No. 12077
3883 Howard Hughes Parkway, Suite 1100
Las Vegas, NV 89169

ORDER
IT IS ORDERED THAT Defendant Rogers shall respond to Plaintiffs’ Complaint on or
before November 10, 2017.
IT IS FURTHER ORDERED THAT Defendants shall respond to Plaintiffs’ Motion for
Remand on or before November 13, 2017.
IT IS SO ORDERED.
DATED: October __, 2017.

_________________________________________
UNITED STATES DISTRICT JUDGE
UNITED STATES MAGISTRATE JUDGE
Dated: October 25, 2017.

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-24827-4902-2290.2