Pappa v. Northstar Location Services, LLC

Filing 6

ORDER granting 4 Stipulation to Extend Time to Answer/Respond re: 1 Complaint. Northstar Location Services, LLC answer due 7/13/2018. Signed by Magistrate Judge Carl W. Hoffman on 7/2/2018. (Copies have been distributed pursuant to the NEF - MMM)

Case 2:18-cv-01023-JAD-CWH Document 4 Filed 06/29/18 Page 1 of 2

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Craig J. Mariam (SBN: 10926)
[e-mail]
GORDON REES SCULLY MANSUKHANI, LLP
300 S. 4th Street, Suite 1550
Las Vegas, NV 89101
Telephone: [phone]
Facsimile: [phone]
Attorneys For Defendant
NORTHSTAR LOCATION SERVICES, LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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300 S. 4th Street, Suite 1550
Las Vegas, NV 89101

Gordon Rees Scully Mansukhani, LLP

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Janis M. Pappa formally known as Janis M. Suarez, )
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Plaintiff,
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vs.
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Northstar Location Services, LLC
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Defendant.
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CASE NO. 2:18-cv-01023-JAD-CWH
Honorable Jennifer A. Dorsey
Magistrate Judge Carl W. Hoffman
STIPULATION TO EXTEND TIME
FOR DEFENDANT NORTHSTAR
LOCATION SERVICES, LLC TO
FILE AND SERVE RESPONSIVE
PLEADING TO COMPLAINT
(First Request)

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TO THIS HONORABLE COURT:

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IT IS HEREBY STIPULATED AND AGREED, by and between Craig J. Mariam, Esq.,

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of the law firm Gordon Rees Scully Mansukhani LLP, attorneys for defendant Northstar

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Location Services, LLC, and Michael Kind, Esq., of the law firm Kazerouni Law Group, APC,

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attorneys for plaintiff Janis M. Pappa, that the date for defendant Northstar Location Services,

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LLC to file and serve a responsive pleading to plaintiff’s Complaint be extended through and

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including July 13, 2018. The reason for the request is that counsel for Northstar Location

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Services, LLC was only very recently retained, and requires additional time to prepare a

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responsive pleading to the Complaint. Additionally, the parties plan to engage in productive

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settlement discussions in an effort to avoid further litigation. As such, the parties require
-1STIPULATION TO EXTEND TIME FOR DEFENDANT NORTHSTAR LOCATION SERVICES, LLC TO FILE
AND SERVE RESPONSIVE PLEADING TO COMPLAINT

Case 2:18-cv-01023-JAD-CWH Document 4 Filed 06/29/18 Page 2 of 2

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additional time to engage in settlement negotiations, in the hopes of avoiding litigation

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altogether.

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This is the parties’ first request for an extension.

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Respectfully submitted,

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DATED this 29th of June, 2018

DATED this 29th day of June, 2018

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/s/ Michael Kind
MICHAEL KIND, ESQ.
Nevada Bar # 13903
KAZEROUNI LAW GROUP, APC
6069 South Fort Apache Road, Suite 100
Las Vegas, NV 89148
Attorneys for Plaintiff

/s/ Craig J. Mariam
CRAIG J. MARIAM, ESQ.
SBN: 10926
GORDON REES SCULLY MANSUKHANI,
LLP
300 S. 4th Street, Suite 1550
Las Vegas, NV 89101
Attorneys for Defendant
Northstar Location Services, LLC

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300 S. 4th Street, Suite 1550
Las Vegas, NV 89101

Gordon Rees Scully Mansukhani, LLP

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ATTESTATION REGARDING SIGNATURES

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I certify that all signatories listed, and on whose behalf the filing is submitted, concur in
the filing’s content and have authorized the filing.

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Dated: June 29, 2018

/s/ Craig J. Mariam
CRAIG J. MARIAM

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IT IS SO ORDERED.

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Dated: July 2, 2018

________________________________
UNITED STATES DISTRICT JUDGE
MAGISTRATE JUDGE

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-2STIPULATION TO EXTEND TIME FOR DEFENDANT NORTHSTAR LOCATION SERVICES, LLC TO FILE
AND SERVE RESPONSIVE PLEADING TO COMPLAINT

Case 2:18-cv-01023-JAD-CWH Document 4-1 Filed 06/29/18 Page 1 of 2

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Craig J. Mariam (SBN: 10926)
[e-mail]
GORDON REES SCULLY MANSUKHANI, LLP
300 S. 4th Street, Suite 1550
Las Vegas, NV 89101
Telephone: [phone]
Facsimile: [phone]
Attorneys For Defendant
NORTHSTAR LOCATION SERVICES, LLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

Gordon Rees Scully Mansukhani, LLP
101 W. Broadway Suite 2000
San Diego, CA 92101

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Janis M. Pappa formally known as Janis M. Suarez, ) CASE NO. 2:18-cv-01023-JAD) CWH
Plaintiff,
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vs.
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Northstar Location Services, LLC
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Defendant.
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PROOF OF SERVICE

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I am a resident of the State of California, over the age of eighteen years, and not a party

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to the within action. One of my business addresses is: Gordon Rees Scully Mansukhani, LLP,

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300 S. 4th Street, Suite 1550, Las Vegas, NV 89101. On June 29, 2018, I served the within

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document:

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1. STIPULATION TO EXTEND TIME FOR DEFENDANT NORTHSTAR
LOCATION SERVICES, LLC TO FILE AND SERVE RESPONSIVE PLEADING
TO COMPLAINT

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
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by transmitting via facsimile the document(s) listed above to the fax number(s) set
forth below on this date before 5:00 p.m.
by personally delivering the document(s) listed above to the person(s) at the
address(es) set forth below.

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BY UNITED STATES MAIL. By placing the documents listed above in a sealed
envelope with postage thereon fully prepaid, in United States mail in the State of
California at San Diego, addressed as set forth below.

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-1PROOF OF SERVICE

Case 2:18-cv-01023-JAD-CWH Document 4-1 Filed 06/29/18 Page 2 of 2

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Gordon Rees Scully Mansukhani, LLP
101 W. Broadway Suite 2000
San Diego, CA 92101

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

by placing a true copy thereof enclosed in a sealed envelope, at a station designated
for collection and processing of envelopes and packages for overnight delivery by
FedEx as part of the ordinary business practices of GORDON REES SCULLY
MANSUKHANI, LLP described below, addressed as follows:
by placing a true copy thereof enclosed in a sealed envelope, at a station designated
for collection and processing of envelopes and packages for overnight delivery by
Express Mail by U.S. post office as part of the ordinary business practices of
GORDON REES SCULLY MANSUKHANI, LLP described below, addressed as
follows:
BY ELECTRONIC FILING. I hereby certify that on June 29, 2018, a copy of the
foregoing documents were filed electronically. Notice of this filing will be sent by
operation of the Court’s electronic filing system to all parties indicated on the
electronic filing receipt. All other parties will be served by regular U.S. Mail. Parties
may access this filing through the Court’s electronic filing system.

Michael Kind
KAZEROUNI LAW GROUP, APC
6069 S. Fort Apache Rd., Suite 100
Las Vegas, NV 89148
Tel: [phone] x7
Fax: [phone]
[e-mail]

Attorneys for Plaintiff

David H. Krieger
HAINES & KRIEGER, LLC
8985 S. Eastern Avenue Suite 350
Henderson, NV 89123
Tel: [phone]
Fax: [phone]
[e-mail]

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I am readily familiar with the firm’s practice of collection and processing correspondence

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for mailing. Under that practice it would be deposited with the U.S. Postal Service on that same

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day with postage thereon fully prepaid in the ordinary course of business. I am aware that on

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motion of the party served, service is presumed invalid if postal cancellation date or postage

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meter date is more than one day after the date of deposit for mailing in affidavit.

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I declare under penalty of perjury under the laws of the United States of America that the
above is true and correct.
Executed on June 29, 2018.
_____________________________
Jeanne P. Farrar

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-2PROOF OF SERVICE