Fioravante et al v. Leica Microsystems, Inc. et al
Filing
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ORDER Granting 9 Stipulation for Extension of Time (First Request) Re: 3 Amended Complaint. Defendants Brandon Elggren and South Ridge Microsurgical, Inc.'s answer due 3/26/2018. Signed by Magistrate Judge Carl W. Hoffman on 2/27/2018. (Copies have been distributed pursuant to the NEF - SLD)
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PICCOLO LAW OFFICES
Matthew C. Piccolo
Nevada State Bar No. 14331
matt@piccololawoffices.com
8565 S. Eastern Ave., Ste. 150
Las Vegas, NV 89123
Telephone: (702) 630-5030
SPAULDING LAW
Brady Brammer
Pro Hac Vice Application Forthcoming
bbrammer@spauldinglaw.com
1955 W. Grove Parkway, Suite 250
Pleasant Grove, UT 84062
Telephone: (801) 839-4653
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Attorneys for Brandon Elggren and
South Ridge Microsurgical, Inc.
___________________________________________________________________________
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IN THE UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
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JOSEPH FIORAVANTE, an individual;
MODERN ORTHOPAEDICS, LLC, a
Nevada Corporation,
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CASE NO. 2:18-cv-00059-GMN-CWH
STIPULATION AND ORDER FOR
EXTENSION OF TIME TO FILE A
RESPONSIVE PLEADING TO
PLAINTIFF’S COMPLAINT
Plaintiff,
vs.
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LEICA MICROSYSTEMS, INC., a
Delaware corporation; SOUTH RIDGE
MICROSURGICAL, INC., a Utah
corporation; STEVE MILAZZO, an
individual (California); BRANDON
ELGGREN, an individual (Utah); DOES I
through X, inclusive; and ROE
CORPORATIONS I through X, inclusive,
(First Request)
Defendants.
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COMES NOW, Plaintiffs Joseph Fioravante and Modern Orthopaedics, LLC,
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(“Plaintiffs”) and Defendants, Brandon Elggren and South Ridge Microsurgical, Inc., collectively
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the (“Applicable Defendants”), through counsel, hereby stipulate and agree pursuant to Local
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Rules 6-1, 6-2 and 7-1 as follows:
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STIPULATION AND ORDER
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STIPULATION
IT IS HEREBY STIPULATED by Plaintiffs and Applicable Defendants that Defendants
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Brandon Elggren and South Ridge Microsurgical, Inc. shall have an extension of time until March
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26, 2018 to file a responsive pleading to Plaintiff’s Amended Complaint [Dkt. 3] in order to allow
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additional time for the Applicable Defendants to evaluate the allegations set forth in the Amended
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Complaint and the factual circumstances underlying such allegations. Plaintiffs are agreeable to
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the requested extension as a matter of professional courtesy. This is the first stipulation for an
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extension of time for the Applicable Defendants to respond to the Amended Complaint.
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IT IS FURTHER STIPULATED by the parties that this stipulation does not constitute any
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waiver of claims for defenses and that the extension of time to file a responsive pleading includes
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an extension to file a Motion to Dismiss pursuant to FRCP 12(b).
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IT IS FURTHER STIPULATED by the parties that this stipulation is made in good faith
and not for the purposes of delay.
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Dated: February 26, 2018
Dated: February 26, 2018
By: _/s/ Matthew C. Piccolo_______
Matthew C. Piccolo
Nevada State Bar No. 14331
PICCOLO LAW OFFICES
8565 S. Eastern Ave., Ste. 150
Las Vegas, NV 89123
By: /s/ M. Lani Esteban-Trinidad*
M. Lani Esteban-Trinidad
Nevada Bar No. 6967
THE THATER LAW GROUP, P.C.
6390 W. Cheyenne Ave, Ste. A
Las Vegas, Nevada 89108
* With Permission
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Attorneys for Defendants Brandon Elggren
and South Ridge Microsurgical, Inc.
Attorneys for Plaintiffs Joseph
Fioravante and Modern Orthopaedics,
LLC
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IT IS SO ORDERED:
February 27, 2018
Dated: ________________
_____________________________________
United States Magistrate/District Judge
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STIPULATION AND ORDER
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CERTIFICATE OF SERVICE
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The undersigned hereby certifies that on February 26, 2018, I caused to be served
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a copy of the foregoing STIPULATION AND ORDER FOR EXTENSION OF
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TIME TO ANSWER PLAINTIFF’S COMPLAINT via the United States District
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Court CM/ECF System upon all parties on the master e-service list.
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Executed: February 26, 2018.
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/s/ Matthew C. Piccolo
Matthew C. Piccolo
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PROOF OF SERVICE
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