Berry v. Aargon Agency, Inc et al

Filing 18

ORDER granting 17 Motion to Extend Time to File Response and Reply to 13 Motion to Dismiss; Responses due by 1/13/2021. Replies due by 2/10/2021. Signed by Judge Andrew P. Gordon on 1/5/2021. (Copies have been distributed pursuant to the NEF - DRS)

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Case 2:20-cv-02144-APG-EJY Document 18 Filed 01/05/21 Page 1 of 2 1 2 3 4 5 6 7 David H. Krieger, Esq. Nevada Bar No. 9086 Shawn W. Miller, Esq. Nevada Bar No. 7825 KRIEGER LAW GROUP, LLC 2850 W. Horizon Ridge Pkwy, Suite 200 Henderson, Nevada 89052 Phone: (702) 848-3855 dkrieger@kriegerlawgroup.com smiller@kriegerlawgroup.com Attorneys for Plaintiff UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 8 9 2850 W. Horizon Ridge Pkwy, Suite 200 Henderson, Nevada 89052 KRIEGER LAW GROUP, LLC 10 WILLIAM BERRY, JR, Plaintiff, 11 12 13 14 15 vs. AARGON AGENCY, INC; PLUSFOUR, INC; QUANTUM COLLECTIONS; AND RICHLAND HOLDINGS, INC DBA ACCOUNTCORP OF SOUTHERN NEVADA, 16 17 18 19 Case No.: 2:20-cv-02144-APG-EJY JOINT MOTION FOR EXTENSION OF TIME FOR PLAINTIFF TO FILE RESPONSE TO DEFENDANT RICHLAND HOLDINGS, INC. DBA ACCOUNTCORP OF SOUTHERN NEVADA’S MOTION TO DISMISS (First Request) Defendants. WILLIAM BERRY, JR (“Plaintiff”) and Defendant RICHLAND HOLDINGS, INC. DBA ACCOUNTCORP OF SOUTHERN NEVDA (“Richland”), collectively the “Parties”, hereby jointly 20 submit this motion (“Joint Motion”) for an extension of time for Plaintiff to file a response to Richland’s 21 Motion to Dismiss (“Motion to Dismiss”) to January 13, 2021. This is the same date Plaintiff’s response 22 is due to Plus Four Inc.’s Motion to Dismiss. Additionally, Richland’s reply brief, if any, shall be 23 24 25 extended to February 10, 2021, the same date Plus Four’s reply brief is due (Plus Four is another Defendant in this matter). Richland’s Motion to Dismiss was filed on December 22, 2020 and appears 26 on the docket as ECF #13. Plaintiff’s current deadline to respond to Richland’s Motion to Dismiss is 27 January 5, 2021. 28 -1- Case 2:20-cv-02144-APG-EJY Document 18 Filed 01/05/21 Page 2 of 2 1 The reason for the request is because of the holidays, counsel for Plaintiff needs additional time 2 to communicate with Plaintiff about the issues raised in the Motion to Dismiss, and fully examine and 3 respond to the arguments and legal analysis set forth in the Motion to Dismiss and evaluate whether 4 dismissal or an amended pleading would resolve the issues raised in the Motion to Dismiss. 5 6 7 This is the Plaintiff’s first request for an extension and this Joint Motion has not been submitted for the purpose of delay or other impermissible purpose. Richland will not be prejudiced by the delay directly affect the other Defendants in this case. Accordingly, it is requested that the Court grant the 10 2850 W. Horizon Ridge Pkwy, Suite 200 Henderson, Nevada 89052 and has agreed to the extensions of time. Additionally, the requested extension will not prejudice or 9 KRIEGER LAW GROUP, LLC 8 extension of time to respond to the Motion to Dismiss to January 13, 2021 and any reply brief to February 11 12 13 14 15 16 17 18 19 10, 2021. Dated: January 5, 2021. Submitted By: No Opposition: /s/ Shawn W. Miller . David H. Krieger, Esq. Shawn W. Miller, Esq. KRIEGER LAW GROUP, LLC 2850 W. Horizon Ridge Pkwy., Suite 200 Henderson, Nevada 89052 Attorneys for Plaintiff /s/ Jared M. Moser . Chad F. Clement, Esq. (NSB 12192) Jared M. Moser, Esq. (NSB 13003) MARQUIS AURBACH COFFING 10001 Park Run Drive Las Vegas, Nevada 89145 Attorneys for Defendant Richland Holdings, Inc., dba AcctCorp of Southern Nevada 20 21 22 23 24 25 ORDER GRANTING EXTENSION OF TIME IT IS SO ORDERED. ________________________________________ UNITED STATES DISTRICT JUDGE 26 27 January 5, 2021 Dated: __________________________________ 28 -2-

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