Bella Layne Holdings, LLC et al v. Southern Nevada Water Authority et al

Filing 24

ORDER Granting 23 Stipulation for Extension of Time re 21 Motion to Dismiss (First Request). Responses due by 8/6/2021. Signed by Judge James C. Mahan on 7/16/2021. (Copies have been distributed pursuant to the NEF - MR)

1

6

MARK E. FERRARIO
Nevada Bar No. 1625
JASON K. HICKS
Nevada Bar No. 13149
GREENBERG TRAURIG, LLP
10845 Griffith Peak Drive, Suite 600
Las Vegas, Nevada 89135
Telephone: [phone]
Fax:
[phone]
Email: [e-mail]
[e-mail]

7

Attorneys for Plaintiffs

2
3
4
5

8

UNITED STATES DISTRICT COURT

9

DISTRICT OF NEVADA

10

Greenberg Traurig, LLP
10845 Griffith Peak Drive, Suite 600
Las Vegas, Nevada 89135
[phone]
[phone] (fax)

11
12

BELLA LAYNE HOLDINGS, LLC, a
Nevada limited liability company; GLOBAL
PEST SERVICES, LLC, a Nevada limited
liability company,

13
14
15
16
17
18
19

Plaintiffs,
v.
SOUTHERN NEVADA WATER
AUTHORITY, a political subdivision of the
State of Nevada; LAS VEGAS VALLEY
WATER DISTRICT; a political subdivision of
the State of Nevada; CITY OF NORTH LAS
VEGAS, a political subdivision of the State of
Nevada; DOE individuals I through X,
inclusive; and ROE entities I through X,
inclusive,

20

Case No.: 2:21-cv-235-JCM-NJK

STIPULATION AND [PROPOSED]
ORDER TO EXTEND TIME FOR
PLAINTIFFS TO FILE THEIR
OPPOSITION TO THE MOTION TO
DISMISS FILED BY DEFENDANTS
SOUTHERN NEVADA WATER
AUTHORITY AND LAS VEGAS
VALLEY WATER DISTRICT (ECF NO.
21) AND JOINDER THERETO BY
DEFENDANT CITY OF NORTH LAS
VEGAS (ECF NO. 22)
First Request

Defendants.

21
22

Plaintiffs Bella Layne Holdings, LLC and Global Pest Services, LLC, and defendants

23

Southern Nevada Water Authority (“SNWA”), Las Vegas Valley Water District (“LVVWD”), and

24

the City of North Las Vegas (“City”), by and through their respective counsel of record, submit this

25

stipulation and request to extend time for plaintiffs to submit their response to the motion to dismiss

26

filed by SNWA and LVVWD (ECF No. 21) and the joinder thereto (ECF No. 22) by the City. This

27

stipulation and request is made and based upon the following:

28
Page 1 of 3
Error! Unknown document property name.

Case 2:21-cv-00235-JCM-NJK Document 23 Filed 07/14/21 Page 2 of 3

1

1.

Plaintiffs filed their amended complaint in this action on June 23, 2021. ECF No. 18.

2

2.

SNWA and LVVWD responded by filing a motion to dismiss the first amended

3

complaint on July 7, 2021. ECF No. 21. The City filed a joinder thereto on July 8, 2021. ECF No.

4

22. Plaintiffs’ response to the motion to dismiss and joinder is presently due July 21, 2021. ECF No.

5

21.

6
7
8
9
10

Greenberg Traurig, LLP
10845 Griffith Peak Drive, Suite 600
Las Vegas, Nevada 89135
[phone]
[phone] (fax)

11

3.

Due to travel and availability issues, the parties have agreed to provide an extension

of time for plaintiffs to file their response to the motion to dismiss and joinder.
4.

Accordingly, the parties stipulate and request that the Court extend plaintiffs’ deadline

to oppose the motion to dismiss the first amended complaint and joinder thereto to August 6, 2021.
5.

This is the first request for an extension of time as it relates to the present motion and

joinder. It is made in good faith and not for purposes of delay.

12

Dated this 14th day of July 2021

Dated this 14th day of July 2021

13

GREENBERG TRAURIG, LLP

LAS VEGAS VALLEY WATER
DISTRICT

/s/ Jason Hicks
MARK E. FERRARIO, ESQ.
Nevada Bar No. 1625
JASON K. HICKS, ESQ.
Nevada Bar No. 13149
10845 Griffith Peak Drive, Suite 600
Las Vegas, Nevada 89135
Attorneys for Plaintiffs

/s/ Brent Gunson
GREGORY J. WALCH, ESQ.
Nevada Bar No. 4780
BRENT D. GUNSON, ESQ.
Nevada Bar No. 8479
JAMES E. SMYTH, ESQ.
Nevada Bar No. 6506
1001 S. Valley View Boulevard, MS #475
Las Vegas, Nevada 89153
Attorneys for defendants Las Vegas Valley
Water District and Southern Nevada Water
Authority

14
15
16
17
18
19
20
21
22
23
24
25
26
27
28

Dated this 14th day of July 2021
CITY OF NORTH LAS VEGAS
/s/ Christopher Craft
MICAELA R. MOORE, ESQ.
Nevada Bar No. 9676
CHRISTOPHER D. CRAFT, ESQ.
Nevada Bar No. 7314
2250 Las Vegas Blvd. North, Suite 810
North Las Vegas, NV 89030
Attorneys for defendant City of North
Las Vegas

Page 2 of 3
Error! Unknown document property name.

1

ORDER

2
3
4
5
6

Based upon the stipulation of the parties, and with good cause appearing, IT IS HEREBY
ORDERED that plaintiffs shall have up to, and including, August 6, 2021 to file a response to
LVVWD’s and SNWA’s motion to dismiss (ECF No. 21) and the City’s joinder thereto (ECF No.
22).
July 16, 2021
Dated this ___ day of ___________ 2021.

7
8
UNITED STATES DISTRICT COURT JUDGE

9
10

Greenberg Traurig, LLP
10845 Griffith Peak Drive, Suite 600
Las Vegas, Nevada 89135
[phone]
[phone] (fax)

11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
Page 3 of 3
Error! Unknown document property name.