Fioravante et al v. Leica Microsystems, Inc. et al

Filing 14

ORDER Granting 13 Stipulation to Extend Time Re: 3 Amended Complaint. Leica Microsystems, Inc. answer due 4/9/2018; Steve Milazzo answer due 4/9/2018. Signed by Magistrate Judge Carl W. Hoffman on 3/23/2018. (Copies have been distributed pursuant to the NEF - ADR)

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Christopher R. Miltenberger
Nevada Bar No. 10153
GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway, Suite 400 North
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Counsel for Defendants Leica Microsystems, Inc.,
and Steve Milazzo

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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JOSEPH FIORAVANTE, an individual;
MODERN ORTHOPAEDICS, LLC, a
Nevada corporation,

GREENBERG TRAURIG, LLP

3773 Howard Hughes Parkway, Suite 400 North
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: [phone]

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Plaintiffs,

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v.

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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,

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Case No. 2:18-cv-00059-GMN-CWH
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINE FOR
DEFENDANTS LEICA
MICROSYSTEMS, INC. AND STEVE
MILAZZO TO RESPOND TO
AMENDED COMPLAINT
(Second Request)

Defendants.

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Pursuant to LR IA 6-1, LR IA 6-2, and LR 7-1, Defendants Leica Microsystems, Inc.

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(“Leica”) and Steve Milazzo (“Milazzo”) and Plaintiffs Joseph Fioravante and Modern

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Orthopaedics, LLC (collectively, “Plaintiffs”), by and through their respective counsel, hereby

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agree to extend the deadline for the Leica and Milazzo to plead or otherwise respond to

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Plaintiffs’ Amended Complaint (ECF No. 3) until April 9, 2018, and request that the Court enter

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an Order approving the same.

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On January 30, 2018, Milazzo was served with process with respect to the Amended

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Complaint in the above-captioned matter. On February 1, 2018, Leica was served with process

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with respect to the Amended Complaint in the above-captioned matter. The parties previously

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stipulated to extend Leica and Milazzo’s deadline to response to the Amended Complaint until

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March 26, 2018 (ECF No. 9), so that counsel could evaluate the allegations set forth in the

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Amended Complaint and the factual circumstances underlying such allegations. The Court

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entered an order approving the stipulation. (ECF No. 10).

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Counsel for Plaintiffs, Leica, and Milazzo are engaged in good faith discussions in an

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effort to attempt to resolve the dispute among themselves without the need for further litigation.

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The parties are in agreement with respect to the extension to allow them to complete their

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discussions prior to Leica and Milazzo having to respond to the Amended Complaint. This is the

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parties’ second stipulation for an extension of time for Defendants Leica and Milazzo to respond

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to the Amended Complaint.

GREENBERG TRAURIG, LLP

3773 Howard Hughes Parkway, Suite 400 North
Las Vegas, Nevada 89169
Telephone: [phone]
Facsimile: [phone]

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Based on the foregoing, the parties respectfully request that the Court enter an order

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extending the deadline for Leica and Milazzo to plead or otherwise respond to the Amended

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Complaint until April 9, 2018.

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Dated: March 22, 2018

Dated: March 22, 2018

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By: /s/ Christopher R. Miltenberger
_ Christopher R. Miltenberger
Nevada Bar No. 10153
GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway
Suite 400 North
Las Vegas, NV 89169

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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

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Attorneys for Plaintiffs Joseph Fioravante
and Modern Orthopaedics, LLC

Attorney for Defendants Leica
Microsystems, Inc. and Steve Milazzo

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IT IS SO ORDERED:

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______________________________________
UNITED STATES
MAGISTRATE/DISTRICT JUDGE

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March 23, 2018
DATED: ____________________

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