Reed v. Convergent Outsourcing, Inc. et al

Filing 9

ORDER Granting 5 Stipulation to Extend Time to Answer/Respond re: 1 Complaint. Convergent Outsourcing, Inc. answer due 3/22/2018. Signed by Magistrate Judge Carl W. Hoffman on 2/28/2018. (Copies have been distributed pursuant to the NEF - MMM)

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LEONARD T. FINK, ESQ.
Nevada Bar No. 6296
NAKESHA S. DUNCAN, ESQ.
Nevada Bar No. 11556
SPRINGEL & FINK LLP
10655 Park Run Drive, Suite 275
Las Vegas, Nevada 89144
Telephone: [phone]
Facsimile: [phone]
E-Mail:
[e-mail]
[e-mail]
Attorneys for Defendant,
CONVERGENT OUTSOURCING, INC.

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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ROBERT REED,
Plaintiff,

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***
Case No.: 2:18-cv-00146-JAD-CWH

vs.
CONVERGENT OUTSOURCING, Inc. and
COMCAST ENTERPRISE SERVICES,
LLC.,

STIPULATION TO EXTEND DEFENDANT
CONVERGENT OUTSOURCING, INC.’S
TIME TO RESPOND TO COMPLAINT
(First Request)

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Defendants.

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Defendant, CONVERGENT OUTSOURCING, INC. (hereinafter “Convergent”) and Plaintiff,
ROBERT REED (hereinafter “Plaintiff” collectively, the “Parties”) stipulate and agree as follows:
Convergent’s time to respond to Plaintiff’s Complaint (ECF No. 1), filed on January 26, 2018,
will be extended from February 20, 2018 to March 22, 2018.

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Convergent requires additional time to investigate Plaintiff’s allegations and respond to Plaintiff’s

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Complaint. Counsel for Convergent only just received notice of this matter on February 22, 2018, and thus,

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{N0397445;1}

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STIPULATION TO EXTEND DEFENDANT CONVERGENT OUTSOURCING, INC.’S TIME TO RESPOND
TO COMPLAINT

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is filing this Stipulation two (2) days after the initial deadline to respond to the Complaint. This is

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Convergent’s first request for an extension.

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DATED this 27th day of February, 2018.

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THE LAW OFFICE OF VERNON NELSON

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By:

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/s/ Melissa Ingleby, Esq.
____________________________________
VERNON NELSON, ESQ.
Nevada Bar No. 6434
MELISSA INGLEBY, ESQ.
Nevada Bar No. 12935
9480 S. Eastern Avenue, Suite 252
Las Vegas, NV 89123
Attorneys for Plaintiff,
ROBERT REED

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SPRINGEL & FINK LLP

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By:

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/s/ Nakesha S. Duncan, Esq.
____________________________________
LEONARD T. FINK, ESQ.
Nevada Bar No. 6296
NAKESHA S. DUNCAN, ESQ.
Nevada Bar No. 11556
10655 Park Run Drive, Suite 275
Las Vegas, Nevada 89144
Attorneys for Defendant,
CONVERGENT OUTSOURCING, INC.

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IT IS SO ORDERED:

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February 28, 2018

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_________________________________________
UNITED STATES DISTRICT JUDGE

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DATED: _________________

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{N0397445;1}

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STIPULATION TO EXTEND DEFENDANT CONVERGENT OUTSOURCING, INC.’S TIME TO RESPOND
TO COMPLAINT

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CERTIFICATE OF SERVICE
Reed v. Convergent Outsourcing, Inc.
United States District Court Case No. 2:18-cv-00146-JAD-CWH

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STATE OF NEVADA

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COUNTY OF CLARK

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I, Julianna K. Ferguson, declare:
I am a resident of and employed in Clark County, Nevada. I am over the age of eighteen years
and not a party to the within action. My business address is 10655 Park Run Drive, Suite 275, Las
Vegas, Nevada, 89144.
On February 27, 2018, I served the document described as STIPULATION TO EXTEND
DEFENDANT CONVERGENT OUTSOURCING, INC.’S TIME TO RESPOND TO
COMPLAINT on the following parties:
VERNON NELSON, ESQ.
Nevada Bar No. 6434
MELISSA INGLEBY, ESQ.
Nevada Bar No. 12935
9480 S. Eastern Avenue, Suite 252
Las Vegas, NV 89123
Tel: [phone]
Fax: [phone]
Attorneys for Plaintiff

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VIA U.S. MAIL: by placing a true copy thereof enclosed in a sealed envelope with postage
thereon fully prepaid, in the United States mail at Las Vegas Nevada. I am “readily familiar”
with the firm’s practice of collection and processing correspondence by mailing. Under that
practice, it would be deposited with the U.S. postal service on that same day with postage fully
prepaid at Las Vegas, Nevada in the ordinary course of business

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VIA FACSIMILE: by transmitting to a facsimile machine maintained by the person on whom it
is served at the facsimile machine telephone number at last given by that person on any document
which he/she has filed in the cause and served on the party making the service. The copy of the
document served by facsimile transmission bears a notation of the date and place of transmission
and the facsimile telephone number to which transmitted. A confirmation of the transmission
containing the facsimile telephone numbers to which the document(s) was/were transmitted will
be maintained with the document(s) served.

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VIA ELECTRONIC SERVICE: by submitting the foregoing to the Court’s E-filing System for
Electronic Service upon the Court’s Service List pursuant to FRCP 5. The copy of the document
electronically served bears a notation of the date and time of service. The original document will
be maintained with the document(s) served and be made available, upon reasonable notice, for
inspection by counsel or the Court.

X

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)
) ss.
)

I declare under penalty of perjury that the foregoing is true and correct.

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/s/ Julianna K. Ferguson

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{N0397445;1}

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An Employee of Springel & Fink LLP

STIPULATION TO EXTEND DEFENDANT CONVERGENT OUTSOURCING, INC.’S TIME TO RESPOND
TO COMPLAINT