Las Vegas Cannabis Awards, LLC et al v. Villano Enterprises, Inc. et al

Filing 7

ORDER Granting #5 Ex Parte Motion for Extension of Time re #1 Complaint (First Request). Defendants answer due 7/12/2021. Signed by Magistrate Judge Cam Ferenbach on 6/7/2021. (Copies have been distributed pursuant to the NEF - MR)

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JAMES D. BOYLE, ESQ.
Nevada Bar No. 08384
E-mail: [e-mail]
JOANNA M. MYERS, ESQ.
Nevada Bar No. 12048
E-mail: [e-mail]
KENDALL LOVELL, ESQ.
Nevada Bar No. 15590
E-mail: [e-mail]
HOLLEY DRIGGS LTD.
400 South Fourth Street, Third Floor
Las Vegas, Nevada 89101
Telephone:
702/791-0308

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Attorneys for Plaintiffs

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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LAS VEGAS CANNABIS AWARDS, LLC, a
Nevada limited liability company; and
SHELDON COOPER, an individual,

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2:21-cv-00900-JAD-VCF

PLAINTIFFS’ EX PARTE
MOTION FOR EXTENSION OF
DEFENDANTS’
TIME TO ANSWER OR RESPOND
TO COMPLAINT

Plaintiffs,

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CASE NO.:

v.
VILLANO ENTERPRISES, INC., a foreign
business entity; CHLOE VILLANO, an
individual d/b/a Villano Enterprises; and CHLOE
VILLANO, an individual,

(First Request)

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Defendants.
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Pursuant to LR IA 6-1, LR IA 6-2, and Fed. R. Civ. P. 6(b), Plaintiffs Las Vegas Cannabis
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Awards, LLC and Sheldon Cooper (together, the “Plaintiffs”), move on an ex parte basis for a 4120
day extension of the time, the fortieth day falling on the prior Sunday, for Defendants Villano
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Enterprises, Inc. and Chloe Villano, individually and d/b/a Villano Enterprises (together, the
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“Defendants”), to answer or otherwise respond to the Complaint filed in this action (ECF No. 1).
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This is the first request for such an extension.
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Plaintiffs hereby submit this motion on an ex parte basis as Defendants are currently
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represented by out-of-state-counsel and have not yet retained Nevada counsel with which Plaintiffs
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could stipulate to the requested extension. Plaintiffs further submit this motion in association with
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Defendants’ out-of-state counsel’s agreement to accept service of process of the Summons and
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-114569-01/2592645_2.docx

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Complaint in this action, by which Plaintiffs may avoid the cost and time expenditures associated

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with personally serving Defendants. Defendants’ out-of-state-counsel has agreed to accept service

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of the Summons and Complaint effective as of May 11, 2021.

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Insofar as Defendants need to identify and engage Nevada counsel, and as a professional

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courtesy in consideration of accepting service of process, Plaintiffs respectfully request that this

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Court grant the consented forty-one-day extension. If granted, Defendants’ time to answer or

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otherwise respond to the Complaint shall be extended as follows:

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Party

Current Deadline

Extended Deadline

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Villano Enterprises, Inc.

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July 12, 2021

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Chloe Villano individually and d/b/a

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July 12, 2021

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Villano Enterprises

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For the reasons set forth above, Plaintiffs respectfully request that the Court grant an
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extension until July 12, 2021 for Defendants to answer or otherwise respond to the Complaint.
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DATED this 4th day of June, 2021.

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HOLLEY DRIGGS LTD.
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/s/ James D. Boyle
JAMES D. BOYLE, ESQ.
Nevada Bar No. 08384
JOANNA M. MYERS, ESQ.
Nevada Bar No. 12048
KENDALL LOVELL, ESQ.
Nevada Bar No. 15590
400 South Fourth Street, Third Floor
Las Vegas, Nevada 89101

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Attorneys for Plaintiffs
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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE

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DATED:

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-214569-01/2592645_2.docx

6-7-2021