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)

Case 2:20-cv-02144-APG-EJY Document 18 Filed 01/05/21 Page 1 of 2

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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: [phone]
[e-mail]
[e-mail]
Attorneys for Plaintiff
UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

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2850 W. Horizon Ridge Pkwy, Suite 200
Henderson, Nevada 89052

KRIEGER LAW GROUP, LLC

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WILLIAM BERRY, JR,
Plaintiff,

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vs.
AARGON AGENCY, INC; PLUSFOUR, INC;
QUANTUM COLLECTIONS; AND
RICHLAND HOLDINGS, INC DBA
ACCOUNTCORP OF SOUTHERN NEVADA,

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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

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submit this motion (“Joint Motion”) for an extension of time for Plaintiff to file a response to Richland’s

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Motion to Dismiss (“Motion to Dismiss”) to January 13, 2021. This is the same date Plaintiff’s response

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is due to Plus Four Inc.’s Motion to Dismiss. Additionally, Richland’s reply brief, if any, shall be

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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

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on the docket as ECF #13. Plaintiff’s current deadline to respond to Richland’s Motion to Dismiss is

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January 5, 2021.

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Case 2:20-cv-02144-APG-EJY Document 18 Filed 01/05/21 Page 2 of 2

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The reason for the request is because of the holidays, counsel for Plaintiff needs additional time

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to communicate with Plaintiff about the issues raised in the Motion to Dismiss, and fully examine and

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respond to the arguments and legal analysis set forth in the Motion to Dismiss and evaluate whether

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dismissal or an amended pleading would resolve the issues raised in the Motion to Dismiss.

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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

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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

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KRIEGER LAW GROUP, LLC

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extension of time to respond to the Motion to Dismiss to January 13, 2021 and any reply brief to February

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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

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ORDER GRANTING EXTENSION OF TIME
IT IS SO ORDERED.
________________________________________
UNITED STATES DISTRICT JUDGE

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January 5, 2021
Dated: __________________________________

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