Gold Water Trading Corporation v. Jinro America, Inc.

Filing 25

ORDER Granting 23 Stipulation to Extend Time. Amended Complaint deadline: 4/12/2018. Signed by Magistrate Judge Cam Ferenbach on 3/14/2018. (Copies have been distributed pursuant to the NEF - ADR)

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Greenberg Traurig, LLP
Suite 400 North, 3773 Howard Hughes Parkway
Las Vegas, Nevada 89169
[phone]
[phone] (fax)

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Kara B. Hendricks (NVSBN 7743)
Christopher R. Miltenberger (NVSBN 10153)
GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway, Suite 400 North
Las Vegas, NV 89169
Telephone: [phone]
[e-mail]
[e-mail]
Christopher Tayback (CA SBN 145532, admitted pro hac vice)
Michael L. Fazio (CA SBN 228601, admitted pro hac vice)
QUINN EMANUEL URQUHART & SULLIVAN, LLP
865 South Figueroa Street, 10th Floor
Los Angeles, California 90017-2543
Telephone: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant Jinro America, Inc.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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GOLD WATER TRADING CORPORATION, a
Nevada corporation,
Plaintiff,

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vs.

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JINRO AMERICA, INC., a foreign corporation;
DOES I-X, inclusive; and ROE Corporations and
Limited Liability Companies I-X, inclusive,

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Defendants.

CASE NO. 2:18-cv-00257 JAD-VCF
STIPULATION AND ORDER: (1)
SETTING DEADLINE FOR
PLAINTIFF TO FILE FIRST
AMENDED COMPLAINT; AND (2)
SETTING DEADLINE FOR
DEFENDANTS TO RESPOND TO
FIRST AMENDED COMPLAINT
(FIRST REQUEST)

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Pursuant to LR IA 6-1, LR IA 6-2, LR 7-1, and FRCP 15(a)(2), Defendant Jinro America,

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Inc. (“JAI”) and Plaintiff Gold Water Trading Corporation (“Gold Water”), by and through their

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respective counsel of record, hereby agree and stipulate to permit Gold Water to file its First

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Amended Complaint on or before April 12, 2018, to extend JAI’s deadline to respond to Gold

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Water’s First Amended Complaint to April 27, 2018, and request that the Court enter an order

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approving the same.

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Gold Water filed its Complaint in this matter in the Eighth Judicial District Court, Clark

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County, Nevada on January 31, 2018. JAI removed the action to this Court on February 12, 2018

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(ECF No. 1). Plaintiff did not move to remand this action.

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On February 16, 2018, Gold Water filed an Emergency Motion for Temporary Restraining

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Order and Preliminary Injunction (the “Motion”) (ECF No. 7). JAI filed its Opposition to the

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Motion on February 21, 2018 (ECF No. 9). Gold Water filed its Reply in support of its Motion on

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February 28, 2018 (ECF No. 17). On March 6, 2018, the Court entered an Order Denying the relief

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sought in the Motion (the “Order”). (ECF No. 20). In the Order, the Court noted that certain “new

Greenberg Traurig, LLP
Suite 400 North, 3773 Howard Hughes Parkway
Las Vegas, Nevada 89169
[phone]
[phone] (fax)

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evidence might cause Gold Water to seek to amend its pleading.” See Order, ECF No. 20, 6:1-2.

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Subsequent to the issuance of the Order, the parties conducted a telephonic meet and confer

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with respect to the status of this action. During this meet and confer, Gold Water indicated that it

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intended to amend its Complaint. In the interests of judicial economy and to reduce the need for the

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parties to file unnecessary documents with the Court, the parties discussed a briefing schedule to

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allow Gold Water to file its First Amended Complaint and for JAI to file its response to Gold

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Water’s First Amended Complaint.

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Based on the foregoing, and pursuant to FRCP 15(a)(2), the parties respectfully request that
the Court enter an order as contemplated by the parties during their meet and confer, as follows:
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Gold Water shall have up to and including April 12, 2018, in which to file and serve

its First Amended Complaint;
2.

JAI shall not have to serve any response to Gold Water’s existing Complaint on file

herein until after the First Amended Complaint is filed;
3.

JAI shall have up to and including April 27, 2018, in which to answer or otherwise

respond to Gold Water’s First Amended Complaint.

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This stipulation is entered into in good faith and is not intended to delay these proceedings.

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Instead, this stipulation will further the interests of justice and judicial efficiency. Nor will any party

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in the action be prejudiced by this stipulation as all parties are in agreement with respect to this

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briefing schedule. Based on the foregoing, good cause exists to enter the order extending the

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parties’ briefing schedule and deadlines as contemplated herein and the parties respectfully request

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that the Court enter an order approving the same.

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Greenberg Traurig, LLP
Suite 400 North, 3773 Howard Hughes Parkway
Las Vegas, Nevada 89169
[phone]
[phone] (fax)

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This is the parties’ first request for an extension of time for either Gold Water to submit an
amended pleading or for JAI to serve a response to any Complaint.
Dated this 13th day of March, 2018.

Dated this 13th day of March, 2018.

GREENBERG TRAURIG, LLP

THE LAW OFFICE OF KAREN H. ROSS

/s/ Christopher R. Miltenberger
Christopher R. Miltenberger (NVSBN 10153)
Kara B. Hendricks (NVSBN 7743)
3773 Howard Hughes Parkway
Suite 400 North
Las Vegas, NV 89169

/s/ Karen H. Ross
Karen H. Ross (NVSBN 9299)
2275 Corporate Circle, Suite 160
Henderson, Nevada 89074

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Christopher Tayback (CA SBN 145532,
admitted pro hac vice)
Michael L. Fazio (CA SBN 228601, admitted
pro hac vice)
QUINN EMANUEL URQUHART &
SULLIVAN, LLP
865 South Figueroa Street, 10th Floor
Los Angeles, California 90017-2543

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Louis E. Garfinkel (NVSBN 3416)
LEVINE, GARFINKEL & ECKERSLEY
2965 S. Jones Blvd., Suite C1-140
Las Vegas, Nevada 89146

Attorneys for Defendant Jinro America, Inc.

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Attorneys for Plaintiff Gold Water Trading
Corporation

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IT IS SO ORDERED:

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______________________________________
UNITED STATES MAGISTRATE/DISTRICT
JUDGE

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3-14-2018
DATED: ____________________

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