Elfberg v. Downtown Project, LLC et al

Filing 10

ORDER Granting 7 Stipulation for Extension of Time re 1 Complaint (First Request). Signed by Magistrate Judge Peggy A. Leen on 10/31/17. (Copies have been distributed pursuant to the NEF - MR)

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SANDRA KETNER, ESQ., Bar # 8527
LITTLER MENDELSON, P.C.
200 S. Virginia Street
8th Floor
Reno, NV 89501
Telephone: [phone]
Fax No.:
775.786.0127
Attorneys for Defendant
DOWNTOWN PROJECT, LLC and
GOLD SPIKE

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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SAVANNAH ELFBERG,
Plaintiff,

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vs.

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DOWNTOWN PROJECT, LLC, a Limited
Liability Company; GOLD SPIKE, a
Nevada business entity,

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Case No. 2:17-cv-02450-JAD-PAL
STIPULATION FOR EXTENSION OF
TIME TO FILE RESPONSIVE PLEADING
[FIRST REQUEST]

Defendants.

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Pursuant to LR IA 6-1 and LR 7-1, Plaintiff SAVANNAH ELFBERG (“Plaintiff”) and

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Defendants DOWNTOWN PROJECT, LLC and GOLD SPIKE (“Defendants”), by and through

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their respective counsel, do hereby stipulate and agree to an extension of thirty (30) days,

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up to and including Wednesday, November 29, 2017, for Defendants to file their first

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responsive pleading to Plaintiff's Complaint.

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LITTLE R MEND ELSO N, P .C .
Attorneys At Law
200 S. Virginia St reet
8th Floor
Reno, NV 89501
775.348.4888

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This Stipulation is made in good faith and not for purposes of delay as defense

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counsel has recently been retained and needs sufficient time to investigate the allegations

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of the Complaint. Additionally, counsel for the parties are discussing the identity of the

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proper defendant in this matter which employed Plaintiff.

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amended complaint will likely be forthcoming in order to narrow the causes of action and

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identify the proper parties so that the filing of a Rule 12(b)(6) motion is avoided.

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Additionally, the parties are discussing the potential for early resolution of this matter.

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Dated: October 26, 2017

The parties believe that an

Dated: October 26, 2017

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TREVOR J. HATFIELD, ESQ.
HATFIELD & ASSOCIATES, LTD.

/s/Trevor J. Hatfield

/s/Sandra Ketner
SANDRA KETNER, ESQ.
LITTLER MENDELSON, P.C.

Attorneys for Plaintiff
SAVANNAH ELFBERG

Attorneys for Defendant
DOWNTOWN PROJECT, LLC and GOLD SPIKE

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ORDER
IT IS SO ORDERED.

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U.S. DISTRICT/MAGISTRATE JUDGE
Dated this 31st day of October, 2017.

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LITTLE R MEND ELSO N, P .C .
Attorneys At Law
200 S. Virginia St reet
8th Floor
Reno, NV 89501
775.348.4888

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PROOF OF SERVICE

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I am a resident of the State of Nevada, over the age of eighteen years, and

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not a party to the within action. My business address is 200 S. Virginia Street, 8th Floor,

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Reno, Nevada 89501. On October 26, 2017, I served the within document(s):

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STIPULATION FOR EXTENSION OF TIME TO FILE
RESPONSIVE PLEADING

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By CM/ECF Filing – Pursuant to FRCP 5(b)(3) and LR 5-4, the abovereferenced document was electronically filed and served upon the parties
listed below through the Court’s Case Management and Electronic Case
Filing (CM/ECF) system:

Trevor J. Hatfield, Esq.
HATFIELD & ASSOCIATES, LTD.
703 South Eighth Street
Las Vegas, NV 89101
[e-mail]

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I am readily familiar with the firm's practice of collection and processing

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correspondence for mailing and for shipping via overnight delivery service. Under that

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practice it would be deposited with the U.S. Postal Service or if an overnight delivery

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service shipment, deposited in an overnight delivery service pick-up box or office on the

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same day with postage or fees thereon fully prepaid in the ordinary course of business.

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I declare under penalty of perjury that the foregoing is true and correct.
Executed on October 26, 2017, at Reno, Nevada.

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LITTLE R MEND ELSO N, P .C .
Attorneys At Law
200 S. Virginia St reet
8th Floor
Reno, NV 89501
775.348.4888

Firmwide:150792056.1 092307.1000

/s/Esperansa Reinold
ESPERANSA REINOLD