JS Products, Inc. v. Roller Clutch Tools, LLC

Filing 35

ORDER Granting 34 Stipulation for Extension of Time re 30 Motion to Dismiss and 7 Motion to Enjoin (Second Request). Responses due by 1/19/2018. Replies due by 1/19/2018. Signed by Chief Judge Gloria M. Navarro on 1/12/2018. (Copies have been distributed pursuant to the NEF - MR)

1 Craig A. Newby (Nevada Bar No. 8591)
McDONALD CARANO, LLP
2 2300 W. Sahara Ave., Ste. 1200
Las Vegas, NV 89102
3 Tel. [phone]
Fax [phone]
4 Email: [e-mail]
5 John B. Sganga, Jr. (Admitted Pro Hac Vice)
Sean M. Murray (Admitted Pro Hac Vice)
6 Joshua Stowell (Admitted Pro Hac Vice)
Justin J. Gillett (Admitted Pro Hac Vice)
7 KNOBBE, MARTENS, OLSON & BEAR, LLP
2040 Main Street, Fourteenth Floor
8 Irvine, CA 92614
Phone: [phone]
9 Facsimile: [phone]
Email: [e-mail]
10 Email: [e-mail]
Email: [e-mail]
11 Email: [e-mail]
12 Attorneys for Plaintiff,
JS Products, Inc.
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FOLEY & OAKES, PC
Daniel T. Foley (Nevada State Bar No.
1079)
626 So. 8th Street
Las Vegas, NV 89101
Telephone: [phone]
Facsimile:
[phone]
Email: [e-mail]
BUETHER JOE & CARPENTER, LLC
ERIC W. BUETHER (to be Admitted Pro
Hac Vice)
Email: [e-mail]
CHRISTOPHER M. JOE (to be Admitted
Pro Hac Vice)
Email: [e-mail]
MICHAEL D. RICKETTS (to be Admitted
Pro Hac Vice)
Email: [e-mail]
1700 Pacific Avenue, Suite 4750
Dallas, Texas 75201
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Defendant,
ROLLER CLUTCH TOOLS, LLC

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IN THE UNITED STATES DISTRICT COURT

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FOR THE DISTRICT OF NEVADA

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JS PRODUCTS, INC., a Nevada corporation,
Plaintiffs,
v.

ROLLER CLUTCH TOOLS, LLC,
22 a California limited liability company,
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Defendant.

Case No. 2:17-cv-02615-GMN-GWF
STIPULATION REGARDING
EXTENSION OF TIME FOR PLAINTIFF
TO RESPOND TO DEFENDANT’S
MOTION TO DISMISS; AND TO REPLY
TO ITS MOTION TO ENJOIN ROLLER
CLUTCH FROM PROSECUTING CASE
AGAINST DEFENDANT BEFORE THE
EASTERN DISTRICT TO TEXAS
(Second Request for Extension to Respond
to Motion to Dismiss)
(Third Request for Extension to Reply to Its
Motion to Enjoin Roller Clutch)

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STIPULATION FOR EXTENSION OF TIME

CASE NO 2:17-CV-02615-GMN-GWF

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Pursuant to Fed. R. Civ. P. 6(b)(1)(A), Local Rules 6-1 and 6-2, Plaintiff JS Products,

2 Inc. (“JS Products” or “Plaintiff”) has requested, and Defendant Roller Clutch Tools, LLC
3 (“Roller Clutch” or “Defendant”) has agreed to, a two week extension of time, until January
4 19, 2018, for Plaintiff to file its Response to Defendant’s Motion to Dismiss for Lack of
5 Personal Jurisdiction Under Fed. R. Civ. P. 12(b)(2) and Improper Venue Under Fed. R. Civ. P.
6 12(b)(3). (ECF No. 30, “Motion”). This is the Parties’ second request for an extension of the
7 deadline to oppose the Motion. The Motion was originally filed on December 15, 2017 and the
8 opposition is currently scheduled to be due on or before January 5, 2018.
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Further, Defendant has also agreed to, a two week extension of time, until January 19,

10 2018, for Plaintiff to file its Reply to Its Motion to Enjoin Roller Clutch Tools, LLC from
11 Prosecuting its Case Against Defendant before the United States District Court for the Eastern
12 District of Texas. (ECF No. 07, “Motion”). This is the Parties’ third request for an extension
13 of the deadline to oppose the Motion. The Motion was originally filed on October 20, 2017,
14 the Opposition (ECF No. 29, “Opposition”) was filed December 15, 2017 and the Reply is
15 currently scheduled to be due on or before January 5, 2018.
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Good cause exists for this Court to grant the extension because the Parties have

17 reached an agreement in principle that settles all matters in controversy between them.
18 The Parties respectfully and jointly request that this Court grant the requested extension to
19 allow the agreement to be finalized, settlement obligations to be met and a dismissal
20 stipulation to be filed with the Court.
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Accordingly, the Parties hereby stipulate that Plaintiff has until January 19, 2018 to

22 file its Opposition to Defendant Roller Clutch’s Motion to Dismiss for Lack of Personal
23 Jurisdiction Under Fed. R. Civ. P. 12(b)(2) and Improper Venue Under Fed. R. Civ. P.
24 12(b)(3); and to Reply to Its Motion to Enjoin Roller Clutch Tools, LLC from Prosecuting its
25 Case Against the Defendant in the matter before the United States District Court for the
26 Eastern District of Texas.
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-1STIPULATION FOR EXTENSION OF TIME

CASE NO 2:17-CV-02615-GMN-GWF

1 Dated: January 4, 2018

MCDONALD CARANO LLP

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/s/ Craig A. Newby
Craig A. Newby (Nevada Bar No. 8591)
Amanda M. Perach (Nevada Bar No. 12399)
2300 W. Sahara Ave., Suite 1200
Las Vegas, NV 89102
Telephone: [phone]
Facsimile:
[phone]
Email: [e-mail]

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John B. Sganga, Jr. (Admitted Pro Hac Vice)
Sean M. Murray (Admitted Pro Hac Vice)
Joshua Stowell (Admitted Pro Hac Vice)
Justin J. Gillett (Admitted Pro Hac Vice)
KNOBBE, MARTENS, OLSON & BEAR, LLP
2040 Main Street, Fourteenth Floor
Irvine, CA 92614
Phone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]
Email: [e-mail]

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Attorneys for Plaintiff, JS Products, Inc.

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-2STIPULATION FOR EXTENSION OF TIME

CASE NO 2:17-CV-02615-GMN-GWF

BUETHER JOE & CARPENTER, LLC

1 Dated: January 4, 2018
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/s/ Michael D. Ricketts
Daniel T. Foley (Nevada State Bar No.1078)
626 So. 8th Street
Las Vegas, NV 89101
FOLEY & OAKES, PC
Telephone: [phone]
Facsimile:
[phone]
Email: [e-mail]

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Eric W. Buether (to be Admitted Pro Hac Vice)
Email: [e-mail]
Christopher M. Joe (to be Admitted Pro Hac Vice)
Email: [e-mail]
Michael D. Ricketts (to be Admitted Pro Hac Vice)
Email: [e-mail]
1700 Pacific Avenue, Suite 4750
Dallas, TX 75201
Telephone: [phone]
Facsimile:
[phone]

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Attorneys for Defendant, Roller Clutch Tools, LLC

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IT IS SO ORDERED.

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DATED this ___day of January, 2018.

___________________________________
Gloria M. Navarro, Chief Judge
UNITED STATES DISTRICT COURT

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-3STIPULATION FOR EXTENSION OF TIME

CASE NO 2:17-CV-02615-GMN-GWF

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CERTIFICATE OF SERVICE

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I HEREBY CERTIFY that I am an employee of McDonald Carano LLP, and that on

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January 4, 2018, I caused a true and correct copy of the foregoing STIPULATION

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REGARDING EXTENSION OF TIME FOR PLAINTIFF TO RESPOND TO

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DEFENDANT’S MOTION TO DISMISS; AND TO REPLY TO ITS MOTION TO

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ENJOIN ROLLER CLUTCH FROM PROSECUTING CASE AGAINST DEFENDANT

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BEFORE THE EASTERN DISTRICT TO TEXAS, to be served via the U.S. District Court’s

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Notice of Electronic Filing (“NEF”) in the above-captioned case to:

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Daniel T. Foley (Nevada State Bar No.1078)
626 So. 8th Street
Las Vegas, NV 89101
Telephone: [phone]
Facsimile:
[phone]
Email: [e-mail]
Eric W. Buether (to be admitted pro hac vice)
Email: [e-mail]
Christopher M. Joe (to be admitted pro hac vice)
Email: [e-mail]
Michael D. Ricketts (to be admitted pro hac vice)
Email: [e-mail]
BUETHER JOE & CARPENTER, LLC
1700 Pacific Avenue, Suite 4750
Dallas, TX 75201
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Defendant,
Roller Clutch Tools, LLC

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/s/ Brian Grubb
An Employee of McDonald Carano LLP

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STIPULATION FOR EXTENSION OF TIME

CASE NO 2:17-CV-02615-GMN-GWF