Derse Inc. v. Ortiz Machine Company, LLC

Filing 8

ORDER granting 6 Motion to Extend Time; Ortiz Machine Company, LLC answer due 3/5/2018. Signed by Magistrate Judge Carl W. Hoffman on 2/27/2018. (Copies have been distributed pursuant to the NEF - JM)

Case 2:18-cv-00192-JAD-CWH Document 6 Filed 02/26/18 Page 1 of 3

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Doreen Spears Hartwell
Nevada Bar No. 7525
Hartwell Thalacker, Ltd.
11920 Southern Highlands Pkwy.
Suite 201
Las Vegas, NV 89141
702-850-1074
[e-mail]

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Attorney for specially appearing Defendant Ortiz Machine
Company, LLC d/b/a Ortiz Gaming

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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DERSE, INC., a Wisconsin Corporation

Case No.: 2:18-cv-00192

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Plaintiff,

DEFENDANT ORTIZ MACHINE
COMPANY, LLC’S UNOPPOSED
MOTION TO EXTEND DEADLINE TO
RESPOND TO COMPLAINT

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v.
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ORTIZ MACHINE COMPANY, LLC,
d/b/a ORTIZ GAMING, a Florida limited
liability company,

(First Request for Extension)

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Defendant.
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Pursuant to FED. R. CIV. P. 6(b) and Local Rule IA 6-1, Defendant Ortiz Machine
Company, LLC (“Ortiz”), by and through its attorneys, without waiving any jurisdictional
objections/defenses, moves for a 1-week extension to file its response to the complaint, and states:

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Pursuant to Fed. R. Civ. P. 12(a)(1)(A)(i), Ortiz’s response to the complaint is currently
due on or before February 26, 2018.

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Ortiz recently retained local counsel in Nevada, and requires additional time to locate,

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organize, and review relevant documents in order to prepare an appropriate response to the

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complaint. This and other matters have prevented Ortiz from completing its response to the

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complaint. Accordingly, Ortiz respectfully seeks a 1-week extension of time, up to and including

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March 5, 2018, to respond to the complaint. This is Ortiz’s first motion to extend the deadline to
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respond to the Complaint.
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DEFENDANT’S MOTION TO EXTEND DEADLINE TO RESPOND TO COMPLAINT

Case 2:18-cv-00192-JAD-CWH Document 6 Filed 02/26/18 Page 2 of 3

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This motion is made in good faith and not for the purpose of delay.

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Plaintiff will not be prejudiced by this limited extension of time given that there are

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currently no scheduled hearings in this case.

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Counsel for Ortiz conferred with Plaintiff’s counsel who stated that Plaintiff agrees with
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the requested extension of time.
Dated: February 26, 2018

Respectfully submitted,
/s/Doreen Spears Hartwell
Doreen Spears Hartwell
Nevada Bar No. 7525
11920 Southern Highlands Pkwy.
Suite 201
Las Vegas, NV 89141
Attorneys for Defendant

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February 27, 2018

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DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT

Case 2:18-cv-00192-JAD-CWH Document 6 Filed 02/26/18 Page 3 of 3

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CERTIFICATE OF SERVICE

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1.

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DEFENDANT ORTIZ GAMING’S UNOPPOSEDD MOTION FOR ETENSION
OF TIME TO RESPOND TO COMPLAINT
2.

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On February 26, 2018, I served the following document(s):

I served the above-named document(s) by the following means to the persons as

listed below:
X

a.

By ECF System:

John Wendland, [e-mail]

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□

b.

By United States Mail, postage full prepaid to:

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c.

By messenger
I served the document(s) by placing them in an envelope or package addressed to

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the persons at the addresses listed below and providing them to a messenger for service:
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d.

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By direct e-mail (as opposed to through the ECF System)
Based upon the written agreement to accept service by e-mail or court order. I

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Anne Freeland, [e-mail]

caused the document(s) to be sent to the persons at the e-mail addresses listed below. I did not
receive, within a reasonable time after the transmission, any electronic message or other indication
that the transmission was unsuccessful.
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e.

By fax transmission
Based upon the written agreement of the parties to accept service by fax transmission

or a court order, I faxed the document(s) to the persons at the fax numbers listed below. No error
was reported by the fax machine that I used. A copy of the record of the fax transmission is attached.
I declare under penalty of perjury that the foregoing is true and correct.
/s/ Doreen Spears Hartwell
An employee of Hartwell Thalacker, Ltd.

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DEFENDANT’S MOTION FOR EXTENSION OF TIME TO RESPOND TO COMPLAINT