Sundance Media Group, LLC v. Yuneec USA, INC

Filing 11

ORDER Granting 10 Motion to Extend Time. Yuneec USA, INC answer due 4/17/2018. Signed by Magistrate Judge Peggy A. Leen on 4/6/2018. (Copies have been distributed pursuant to the NEF - ADR)

Case 2:18-cv-00388-APG-PAL Document 10 Filed 04/03/18 Page 1 of 3

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PAUL S. PADDA, ESQ. (NV Bar #10417)
Email: [e-mail]
JOSHUA Y. ANG, ESQ. (NV Bar #14026)
Email: [e-mail]
PAUL PADDA LAW, PLLC
4560 South Decatur Blvd., Suite 300
Las Vegas, Nevada 89103
Tele: [phone]
Fax: [phone]
Attorneys for Defendant

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA
SUNDANCE MEDIA GROUP, LLC,

4560 South Decatur Blvd., Suite 300
Las Vegas, Nevada 89103
Tele: [phone] • Fax [phone]

PAUL PADDA LAW, PLLC

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Plaintiff,

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Case No. 2:18-cv-0388-APG-PAL
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vs.

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YUNEEC USA, INC., Does I through X and
Roe Corporations I through X inclusive,

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Defendants.

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DEFENDANT YUNEEC USA, INC.’S MOTION FOR EXTENSION OF TIME
TO RESPOND TO PLAINTIFF’S COMPLAINT

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(FIRST REQUEST)

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Pursuant to Federal Rule of Civil Procedure (“FRCP”) 6(b)(1)(A) and the Court’s Local

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Rule 7-2, Defendant Yuneec USA, Inc. (“Yuneec”) respectfully requests a 14-day extension of

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time, to and until April 17, 2018, to respond to Plaintiff’s Complaint. Yuneec’s response is due

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today, April 3, 2018. 1 This is Yuneec’s first request for an extension of time to respond to

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Plaintiff’s Complaint.

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. . .

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FRCP 12(a)(1) provides that a defendant must serve an answer within 21-days after being
served with the summons and complaint.
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Case 2:18-cv-00388-APG-PAL Document 10 Filed 04/03/18 Page 2 of 3

In support of this motion, Plaintiff relies upon the memorandum of points and

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authorities below.

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MEMORANDUM OF POINTS AND AUTHORITIES

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Under FRCP 6(b)(1)(A), a party may seek to extend a deadline prior to its expiration

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upon a showing of “good cause.” The standard to be applied by a court under FRCP 6(b)(1) is a

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liberal one in order to “effectuate the general purpose of seeing that cases are tried on the

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merits.” Ahanchian v. Xenon Pictures, Inc., 624 F.3d 1253, 1258-59 (9th Cir. 2010). Good

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cause “is a non-rigorous standard that has been construed broadly across procedural and

4560 South Decatur Blvd., Suite 300
Las Vegas, Nevada 89103
Tele: [phone] • Fax [phone]

PAUL PADDA LAW, PLLC

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statutory contexts.” Id at 1259.
In this case, good cause exists to provide Yuneec with a short two-week extension of

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time to respond to Plaintiff’s Complaint. Undersigned counsel, whose law firm was only just

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today (April 3, 2018) retained by Yuneec, needs additional time to review the Complaint,

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discuss the allegations set forth in that pleading with Yuneec’s management and formulate an

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appropriate response. Yuneec is also represented by counsel based in California, specifically

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Douglas Q. Hahn, Esq. and Salil Bali, Esq. of the law firm Stradling Yocca Carlson & Rauth,

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P.C. Undersigned counsel has discussed the allegations set forth in Plaintiff’s Complaint with

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Messrs. Hahn and Bali and is in the process of coordinating an appropriate response with them

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but, as referenced above, must also ensure that Yuneec management review the response and
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provide their input. 2 The additional time requested herein will provide undersigned counsel

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sufficient time to accomplish the foregoing.

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. . .

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The additional time is also needed to permit California counsel, who have a prexisting
attorney/client relationship with Yuneec, sufficient time to prepare an application for admission
to this Court.
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Case 2:18-cv-00388-APG-PAL Document 10 Filed 04/03/18 Page 3 of 3

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CONCLUSION
For the reasons set forth above, good cause exists to grant Defendant Yuneec a short 14day extension of time to file a response to Plaintiff’s Complaint.

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Respectfully submitted,

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/s/ Paul S. Padda

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_____________________________

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Paul S. Padda, Esq.

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Counsel for Defendant Yuneec

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Dated: April 3, 2018

4560 South Decatur Blvd., Suite 300
Las Vegas, Nevada 89103
Tele: [phone] • Fax [phone]

PAUL PADDA LAW, PLLC

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IT IS SO ORDERED:
The Court having reviewed Defendant Yuneec
USA, Inc.’s motion for a 14-day extension of
time to respond to Plaintiff’s Complaint, it is
hereby ordered that the motion is granted.
Yuneec shall file a response to Plaintiff’s
Complaint on or before April 17, 2018.

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____________________________________
UNITED STATES MAGISTRATE JUDGE

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April 6, 2018
DATED: ____________________

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CERTIFICATE OF SERVICE
Pursuant to the Federal Rules of Civil Procedure and the Court’s Local Rules, the
undersigned hereby certifies that on this day, April 3, 2018, a copy of the foregoing document
was served upon all registered parties and their counsel through the Court’s electronic filing
system (CM/ECF).

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/s/ Paul S. Padda
_____________________________
Paul S. Padda, Esq.

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