Whittemore v. Anderson Financial Services, LLC et al

Filing 101

ORDER Granting 100 Stipulation for Extension of Time Re: 92 Motion to Dismiss. Replies due by 6/8/2021. Signed by Judge Gloria M. Navarro on 6/3/2021. (Copies have been distributed pursuant to the NEF - JQC)

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1 2 3 4 5 6 7 8 9 10 11 12 13 PHILIP J. TRENCHAK, ESQ. Nevada Bar No. 9924 MULLINS & TRENCHAK, ATTORNEYS AT LAW 1614 S. Maryland Pkwy Las Vegas, Nevada 89104 Tel: (702) 778-9444 Fax: (702) 778-9449 E-mail: phil@mullinstrenchak.com Attorneys for Plaintiff/Counter-Defendant -ANDJENNY L. FOLEY, Ph.D., ESQ. Nevada Bar No. 9017 E-mail: jfoley@hkm.com HKM EMPLOYMENT ATTORNEYS LLP 1785 East Sahara, Suite 300 Las Vegas, Nevada 89104 Tel: (702) 805-8340 Fax: (702) 805-8340 E-mail: jfoley@hkm.com Attorneys for Plaintiff/Counter-Defendant 14 UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 15 16 17 KATELYN WHITTEMORE, an individual, CASE NO.: 2:19-cv-01951-GMN-EJY Plaintiff, 18 19 vs. 20 ANDREW “TOBY” MATHIS, an individual, CLINT COONS, an individual, MICHAEL BOWMAN, an individual, RAYMOND “KENNER” FRENCH, an individual, VAST HOLDINGS GROUP, LLC, doing business as a Nevada limitedliability company; ANDERSON FINANCIAL SERVICES, LLC, doing business as a foreign Washington limitedliability company; VAST SOLUTIONS GROUP, INC., a Nevada Corporation, VAST FINANCIAL SOLUTIONS, INC., a Nevada Domestic Corporation; 21 22 23 24 25 26 27 STIPULATION AND ORDER TO REPLY TO DEFENDANTS’/ COUNTERCLAIMANTS’ RESPONSE IN OPPOSITION TO PLAINTIFF’S/COUNTERDEFENDANT’S ANTI-SLAPP SPECIAL MOTION TO DISMISS PURSUANT TO NRS 41.637 28 Page 1 of 4 (FIRST REQUEST) 1 2 3 4 GRAPHENE ADVISORS LLC, a Nevada Limited Liability Company, VAST SOLUTIONS GROUP, LLC, a Washington Limited Liability Company; and Anderson Investment Consultants, LLC; DOES 1-100, inclusive. 5 Defendants. 6 7 8 9 10 11 12 VAST HOLDING GROUP, LLC, a Nevada limited liability company, VAST SOLUTIONS GROUP, INC., a Nevada Corporation, GRAPHENE ADVISORS LLC, A Nevada Limited Liability Company, VAST SOLUTIONS GROUP, LLC, A Washington Limited Liability Company, RAYMOND “KENNER” FRENCH, an individual, 13 Counterclaimants, 14 v. 15 KATELYN WHITTEMORE, an individual, and DOES I-X, and ROE CORPORATIONS I-X, inclusive, 16 17 18 19 20 21 22 Counter-Defendants. Plaintiff/Counter-Defendant KATELYN WHITTEMORE (“Plaintiff”) and Defendants/Counterclaimants VAST HOLDINGS GROUP, LLC, VAST SOLUTIONS GROUP, INC., VAST SOLUTIONS GROUP, LLC, VAST FINANCIAL SOLUTIONS, INC., 23 GRAPHENE ADVISORS, LLC, ANDERSON INVESTMENT CONSULTANTS, LLC AND 24 R. KENNER FRENCH (“Defendants”), by and through their counsel of record, hereby stipulate 25 to extend the deadline for Plaintiff to reply to Defendants’ Response in Opposition to Plaintiff’s 26 27 28 Anti-SLAPP Special Motion to Dismiss pursuant to NRS 41.637 (ECF 99), which was filed on May 11, 2021. The parties hereby stipulate and agree as follows: Page 2 of 4 1 2 1. Plaintiff’s reply to Defendants’ Response in Opposition to Plaintiff’s Anti-SLAPP Special Motion to Dismiss pursuant to NRS 41.637 (ECF 99) is currently due on May 18, 2021. 3 2. In order to avoid unnecessary time and expense in connection with motions to 4 dismiss and other litigation matters pertaining to Defendants’ Response in Opposition to Plaintiff’s 5 Anti-SLAPP Special Motion to Dismiss pursuant to NRS 41.637 (ECF 99), Plaintiff and 6 Defendants have agreed to extend the time by which Plaintiff shall be required to reply to 7 Defendants’ Response in Opposition to Plaintiff’s Anti-SLAPP Special Motion to Dismiss 8 pursuant to NRS 41.637 (ECF 99) by a period of two (2) weeks. 9 3. Pursuant to this agreement between the parties, Plaintiff shall be required to file a 10 reply to Defendants’ Response in Opposition to Plaintiff’s Anti-SLAPP Special Motion to Dismiss 11 pursuant to NRS 41.637 (ECF 99) or before June 8, 2021. 12 4. The parties agree that good cause exists for the request for the extension of the 13 deadline for a reply to Defendants’ Response in Opposition to Plaintiff’s Anti-SLAPP Special 14 Motion to Dismiss pursuant to NRS 41.637 (ECF 99) for the above-specified reasons. 15 16 /// 17 18 /// 19 20 /// 21 22 /// 23 24 /// 25 26 /// 27 28 /// Page 3 of 4 1 2 5. The parties agree that the requested extension is warranted under the current circumstances and will not result in an undue or significant delay in the administration of this case. 3 Dated this 26th day of May, 2021. Dated this 26th day of May, 2021. 4 HKM EMPLOYMENT ATTORNEYS LLP HOLLEY DRIGGS /s/ Jenny L Foley Jenny L. Foley, Ph.D., Esq. Nevada Bar No. 9017 1785 East Sahara Ave., Suite 300 Las Vegas, Nevada 89104 /s/ Kristol Bradley Ginapp Kristol Bradley Ginapp, Esq. 400 South Fourth Street, 3rd Floor Las Vegas, NV 89101 5 6 7 8 9 10 11 12 13 14 Philip J. Trenchak, Esq. Victoria C. Mullins, Esq. MULLINS & TRENCHAK, ATTORNEYS AT LAW 1614 S. Maryland Parkway Las Vegas, NV 89104 Attorneys for Defendants Vast Holdings Group, LLC, Vast Solutions Group, Inc., Vast Solutions Group, LLC, Vast Financial Solutions, Inc., Graphene Advisors, LLC, and R. Kenner French Attorneys for Plaintiff 15 ORDER 16 IT IS SO ORDERED nunc pro tunc. 17 3 Dated this __ day of May, 2021. June 18 19 20 21 22 Gloria M. Navarro, District Judge United States District Court 23 24 25 26 27 28 Page 4 of 4

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