Martin v. James River Insurance Company

Filing 16

ORDER Granting 12 Stipulation for Extension of Time re 7 Motion to Dismiss (First Request). Responses due by 7/6/2018. Signed by Judge Andrew P. Gordon on 7/3/2018. (Copies have been distributed pursuant to the NEF - MR)

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JASON R. MAIER , ESQ.
Nevada Bar No. 8557
Stephen G. Clough, Esq.
Nevada Bar No. 10549
MAIER GUTIERREZ & ASSOCIATES
8816 Spanish Ridge Avenue
Las Vegas, Nevada 89148
Telephone: [phone]
Facsimile: 702.629.7925
E-mail:
[e-mail]
[e-mail]

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Attorneys for Plaintiff Matthew J. Martin

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MATTHEW J. MARTIN, an individual,

Case No.: 2:18-CV-00985-APG-VCF

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Plaintiff,
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vs.

STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR PLAINTIFF
JAMES RIVER INSURANCE COMPANY, a TO FILE A RESPONSE TO DEFENDANT’S
foreign corporation; DOES I-X; and ROE MOTION TO DISMISS [ECF NO. 7]
CORPORATIONS I-X, inclusive

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Defendants.

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Plaintiff MATTHEW J. MARTIN, by and through his counsel of record, the law firm MAIER

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GUTIERREZ & ASSOCIATES, and Defendant JAMES RIVER INSURANCE COMPANY, by and

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through its counsel of record, the law firms NEMECEK & COLE, PC and BREMER WHYTE BROWN &

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O’MEARA, LLP, hereby stipulate and agree, subject to the Court’s approval, as follows:

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1.

On April 24, 2018, plaintiff filed his complaint in the Eighth Judicial District Court,

County of Clark, Nevada [ECF No. 1];
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On May 31, 2018, defendant filed a petition for removal of action under 28 U.S.C. Sec.

1441(b) [ECF No. 1];

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3.

Defendant filed a motion to dismiss [ECF No. 7] on June 7, 2018.

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4.

Plaintiff’s response to the motion to dismiss is currently due on June 21, 2018.

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5.

It is hereby stipulated that plaintiff be permitted a two week extension of time to file a

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response to defendant’s motion to dismiss, extending the filing deadline to July 6, 2018.
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6.

It is further stipulated that defendant be permitted a reciprocal extension of time to file

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its reply to plaintiff’s response to defendant’s motion to dismiss, extending the filing deadline for the

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reply to July 20, 2018

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7.

This is the first stipulation for extension of time to respond to the motion to dismiss

[ECF No. 7].
IT IS RESPECTFULLY SUBMITTED, AGREED AND STIPULATED.

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DATED this ____ day of June, 2018.

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DATED this ___ day of June, 2018.

MAIER GUTIERREZ & ASSOCIATES

NEMECEK & COLE

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/s/ Stephen G. Clough
JASON R. MAIER, ESQ.
Nevada Bar No. 8557
STEPHEN G. CLOUGH, ESQ.
Nevada Bar No. 10549
8816 Spanish Ridge Avenue
Las Vegas, Nevada 89148
Attorneys for Plaintiff

/s/ Matthew J. Hafey
MATTHEW J. HAFEY, ESQ.
California Bar No. 167122 (pro hac vice)
15260 Ventura Boulevard, Suite 920
Sherman Oaks, CA 91403
BREMER WHYTE BROWN & O’MEARA
JOHN V. O’MEARA, ESQ.
Nevada Bar No. 7467
LUCIEN GRECO, ESQ.
Nevada Bar No. 10600
1160 N. Town Center Drive, Suite 250
Las Vegas, Nevada 89144
Attorneys for Defendant

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ORDER

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IT IS SO ORDERED. The deadline for plaintiff to file a response to defendant’s motion to
dismiss is extended until July 6, 2018.
Dated: July 3, 2018.
DATED this ____ day of _________________, 2018.

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UNITED STATES DISTRICT JUDGE
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