EB Holdings II, Inc. et al v. Illinois National Insurance Company et al

Filing 22

ORDER granting #20 Stipulation to Extend Time to Respond to #1 Complaint. Illinois National Insurance Company answer due 1/15/2021. Signed by Magistrate Judge Nancy J. Koppe on 1/7/2021. (Copies have been distributed pursuant to the NEF - HAM)

Case 2:20-cv-02248-JCM-NJK Document 20 Filed 01/06/21 Page 1 of 3
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01/07/21

1 CARLETON R. BURCH
Nevada Bar No. 10527
2 [e-mail]
JANIECE S. MARSHALL
3 Nevada Bar No. 4686
[e-mail]
4 ANDERSON, McPHARLIN & CONNERS LLP
601 S. Seventh Street
5 Las Vegas, Nevada 89101
TELEPHONE: [phone] FACSIMILE: [phone]
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Attorneys for Defendant Illinois National
7 Insurance Company
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

11 EB HOLDINGS II, INC. and QXH II, INC.,

TEL

LAWYERS
601 S. SEVENTH STREET
LAS VEGAS, NEVADA 89101
[phone] • FAX [phone]

ANDERSON, MCPHARLIN & CONNERS LLP

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Plaintiffs,

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vs.

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NATIONAL
INSURANCE
14 ILLINOIS
COMPANY; CONTINENTAL CASUALTY
15 COMPANY and FEDERAL INSURANCE
COMPANY,
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Defendants.
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Case No. 2:20-cv-02248-JCM-NJK
STIPULATION TO EXTEND TIME FOR
DEFENDANT ILLINOIS NATIONAL
INSURANCE COMPANY TO ANSWER
COMPLAINT
(FIRST REQUEST)

Pursuant to LR-6-1, 6-2 and 7-1 Defendant ILLINOIS NATIONAL INSURANCE
COMPANY (“Illinois National”), by and through its counsel Carleton R. Burch of the law firm of
Anderson McPharlin & Conners LLP and Plaintiffs EB HOLDINGS II, INC., by and through its
counsel Talitha Gray Kozlowski of the law firm of Garman Turner Gordon LLP and QXH II, INC.,
by and through its counsel Paul C. Fuener of the law firm K&L Gates LLP, have agreed to extend
the time for Defendant Illinois National to respond to Plaintiffs’ Complaint to January 15, 2021. 1
This request is for good cause and not for undue delay given:

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The parties submitted a prior stipulation to extend the time; however, this Court denied the
extension, without prejudice, as the prior stipulation did not comport with LR IA 6-1 as it failed to
28 give a reason for the requested extension.
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Case No. 2:20-cv-02248-JCM-NJK
2305483.1 05735-105-A

Case 2:20-cv-02248-JCM-NJK Document 20 Filed 01/06/21 Page 2 of 3
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1.

Plaintiffs Eb Holdings and QXH II filed their Complaint on or about December 11,

2.

Defendant Illinois National Insurance Company’s answer to the Complaint is

2 2020.
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4 currently due on or before January 6, 2021.
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3.

Defendant Illinois National Insurance Company seeks an extension to answer the

6 Complaint from January 6, 2021 to January 15, 2021.
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4. Defendant Illinois National Insurance Company requires additional time to adequately

8 prepare the answer to the Complaint as a result of:
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(a)

Pre-existing professional commitments of its counsel in other matters

11 v. Golden Boy Promotions, Inc., Case A-16-73956, before the Nevada Supreme Court filed on
12 January 4, 2021;
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(b)

Delays resulting from COVID-19 pandemic due to the closing of the legal

14 offices in both California and Nevada as well as client representatives working remotely and in
15 different time zones; and
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(c)

The recent state and federal holidays which has shortened working days to

TEL

LAWYERS
601 S. SEVENTH STREET
LAS VEGAS, NEVADA 89101
[phone] • FAX [phone]

ANDERSON, MCPHARLIN & CONNERS LLP

10 including, but not limited, to preparing the Respondent’s Brief in Pound for Pound Promotions, Inc.

17 prepare answers in conjunction with the already scheduled vacation time of counsel around the
18 holidays.
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2305483.1 05735-105-A

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Case No. 2:20-cv-02248-JCM-NJK

Case 2:20-cv-02248-JCM-NJK Document 20 Filed 01/06/21 Page 3 of 3
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5.

There have been no other extensions of time to answer the Complaint in this matter.

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IT IS SO STIPULATED:

3 Dated this 5th day of January 2021.
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GARMAN TURNER GORDON LLP

K&L GATES LLP

/s/Talitha Gray Kozlowski
GREGORY E. GARMAN, ESQ.
TALITHA GRAY KOZLOWSKI, ESQ.
TERESA M. PILATOWICZ, ESQ.
7251 Amigo Street, Suite 210
Las Vegas, Nevada 89119
Attorneys for EB Holdings II, Inc.

/s/ Paul C. Fuener
THOMAS E. BIRSIC, ESQ.
PAUL C. FUENER, ESQ.
K&L Gates Center
210 Sixth Avenue
Pittsburgh, Pennsylvania 15222

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ANDERSON, McPHARLIN & CONNERS LLP

/s/ Carleton Burch
CARLETON R. BURCH, ESQ.
JANIECE S. MARSHALL, ESQ.
601 S. Seventh Street
Las Vegas, Nevada 89101
Attorneys for Illinois National Insurance
Company

TEL

LAWYERS
601 S. SEVENTH STREET
LAS VEGAS, NEVADA 89101
[phone] • FAX [phone]

ANDERSON, MCPHARLIN & CONNERS LLP

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GHANDI DEETER BLACKHAM
SHARA L. LARSON, ESQ.
725 S. 8th Street, Suite 100
Las Vegas, Nevada 89101
Attorneys for QXH II, Inc.

ORDER

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IT IS SO ORDERED.

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Dated: January 7, 2021

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UNITED STATES DISTRICT COURT JUDGE
United States Magistrate Judge

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2305483.1 05735-105-A

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Case No. 2:20-cv-02248-JCM-NJK