Amtrust International Underwriters v. Findlay, et al

Filing 33

ORDER granting 26 Motion to Extend Time to Answer/Respond re: 4 Amended Complaint. Windmill Farms, Inc. answer due 8/13/2018. Signed by Magistrate Judge Cam Ferenbach on 8/10/2018. (Copies have been distributed pursuant to the NEF - MMM)

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PAUL C. RAY, ESQ.
Nevada Bar No. 4365
PAUL C. RAY, CHTD.
8670 West Cheyenne Avenue, Suite 130
Las Vegas, NV 89129
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]

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Attorneys for Windmill Farms, Inc.
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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AMTRUST INTERNATIONAL
UNDERWRITES, DAC, f/k/a AMTRUST
INTERNATIONAL UNDERWRITERS,
LIMITED,

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Plaintiff,

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Case No. 2:18-cv-00652-JCM-VCF
JOINT MOTION TO EXTEND TIME
FOR DEFENDANT WINDMILL
FARMS, INC. TO ANSWER
COMPLAINT

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vs.

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CLIFFORD J. FINDLAY and DONNA SUE
FINDLAY, individually and as Trustees, CLIFF
FINDLAY AND DONNA S. FINDLAY
FAMILY TRUST, DATED FEBRUARY 20,
1986; FINDLAY MANAGEMENT GROUP;
FINDLAY-NOLTE AUTOMOTIVE, LLC;
CLIFF FINDLAY AUTOMOTIVE, LLC;
FINDLAY AUTO HOLDINGS, LLC; CLIFF
FINDLAY AUTO CENTER; TYLER CORDER;
AND WINDMILL FARMS, INC.,

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(SECOND REQUEST)

Defendant.

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Amtrust International Underwrites, Limited and Windmill Farms, Inc.by and through
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their undersigned respective counsels of record, file this JOINT MOTION TO EXTEND TIME
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FOR DEFENDANT WINDMILL FARMS, INC. TO ANSWER COMPLAINT
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(SECOND REQUEST) pursuant to Local Rule 6-1.
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Windmill Farms, Inc.’s Answer and/or Response to the Complaint is presently scheduled
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to be due July 14, 2018 by the Court’s June 28, 2018 order at (22). The underlying state court
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case, Case No. A-16-735002-B, in the Eighth Judicial District Court, Clark County, Nevada, is
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scheduled for decision by the Honorable Nancy L. Allf upon submitted Findings of Fact,

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Conclusions of Law and objections thereto on July 24, 2018 and for entry of judgment the

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following week.

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To allow the parties to determine which, if any parties pertaining to the underlying state

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court case will remain in this case, the parties jointly move to allow Windmill farms, Inc. and

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additional 30 days to file its answer or to otherwise plead in response to the complaint. This is

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the second request for extension of time.

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DATED this 10th day of July, 2018.

DATED this 10th day of July, 2018.

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PAUL C. RAY, CHTD.

WILSON. ELSER, MOSKOWITZ,
EDELMAN & DICKER, LLP

BY: /s/ Paul C. Ray
PAUL C. RAY, ESQ., NV Bar No. 4365
8670 W. Cheyenne Avenue, Suite 130
Las Vegas, NV 89129
Telephone: [phone]
Facsimile: 702.823.2384
Email: [e-mail]

BY: /s/ Sheri Thome
Sheri Thome, Esq.
Nevada Bar No. 08657
300 South Fourth Street, 11th Floor
Las Vegas, NV 89101
Telephone: [phone]

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and
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Attorneys for Windmill Farms, Inc.
RUBERRY, STALMACK & GARVEY,
LLC
Edward F. Ruberry, Esq.
Illinois Bar No. 2411547
Rostylaw J. Smyk, Esq.
Illinois Bar No. 6255495
Dennis B. Condon, Esq.
Illinois Bar No. 6206691
10 South LaSalle Street, Suite 1800
Chicago, Illinois, 60603
Tel: [phone] Fax: [phone]
ed.ruberry@ruberry-law,com
[e-mail]
[e-mail]
Attorneys for Plaintiff, Amtrust International
Underwriters, Limited

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ORDER
IT IS HEREBY ORDERED that Defendant Windmill Farms, Inc.’s Answer and/or
August 13
Response to the Complaint must be filed on or before ________________, 2018.

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_______
UNITED STATES MAGISTRATE JUDGE
DATED: August 10

, 2018.

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CERTIFICATE OF SERVICE
Pursuant to Fed R. Civ. P. 5(b), I certify that on the 10th day of July 2018, the foregoing

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Joint Motion to Extend Time for Defendant Windmill Farms, Inc. To Answer Complaint

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was submitted electronically for filing and service with the United States District Court of

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Nevada using the ECF system for notification of such filing to all the proper parties.

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/s/ Paul C. Ray
_________________________
Paul C. Ray, Esq.

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