Hillcrest Investments. Ltd. et al v. American Borate Company et al

Filing 96

ORDER Granting 95 Stipulation for extension of time to respond to 64 Motion for Sanctions. Responses due by 12/9/2022. Signed by Judge Richard F. Boulware, II on 11/21/2022. (Copies have been distributed pursuant to the NEF - LOE)

Case 2:21-cv-00964-RFB-NJK Document 96 Filed 11/21/22 Page 1 of 2

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KAREN L. HANKS, ESQ.
Nevada Bar No. 9578
E-mail: [e-mail]
HANKS LAW GROUP
7625 Dean Martin Drive, Suite 110
Las Vegas, Nevada 89139
Telephone: [phone]
Attorneys for Plaintiff Hillcrest Investments, Ltd.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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HILLCREST INVESTMENTS, LTD., a
Canadian Corporation; AMERGOSA
ENTERPRISE, LLC.,

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Case No. 2:21-cv-00964-RFB-NJK

Plaintiffs,

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vs.

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AMERICAN BORATE COMPANY, a foreign
corporation; AMERICAN BORATE
COMPANY of Texas, a foreign corporation;
STATE ENGINEER, STATE OF NEVADA;
DEPARTMENT OF CONSERVATION AND
NATURAL RESOURCES, DIVISION OF
WATER RESOURCES, a Nevada Political
Subdivision; RAMM CORPORATION, a
Nevada Corporation; UNITED STATES FISH
AND WILD SERVICE, a division of the
UNITED STATES; NATIONAL PARK
SERVICE, a division of the UNITED
STATES; DOES I – V; and ROES VI – X,

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STIPULATION AND ORDER TO
EXTEND DEADLINE TO FILE
RESPONSE TO
DEFENDANTS’AMERICAN BORATE
COMPANY AND AMERICAN BORATE
COMPANY OF TEXAS’ RENEWED
MOTION FOR SANCTIONS
(ELEVENTH REQUEST)

Defendants.

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Plaintiffs, HILLCREST INVESTMENTS, LTD. and AMERGOSA ENTERPRISE, LLC

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(“Plaintiffs”), Defendants, AMERICAN BORATE COMPANY AND AMERICAN BORATE

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COMPANY OF TEXAS (collectively “American Borate”) and non-party attorney BYRON

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THOMAS, ESQ., (“Thomas”) hereby stipulate and agree as follows:

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On June 28, 2022, American Borate filed a renewed motion for sanctions against Plaintiffs

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and Thomas. Based on the filing of a previous stipulation, Plaintiffs’ and Thomas’ response is due

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November 18, 2022. Hillcrest and American Borate have diligently been negotiating settlement.

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Case 2:21-cv-00964-RFB-NJK Document 96 Filed 11/21/22 Page 2 of 2

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American Borate needs additional time to consider the Plaintiffs’ and Thomas’ latest offer. As a

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result, the parties agree to extend Plaintiffs’ and Thomas’ response deadline to December 9, 2022.

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The parties do not seek this extension to cause delay or prejudice any party.

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Dated this 18th day of November, 2022.

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HANKS LAW GROUP

LEONARD LAW, PC

/s/ Karen L. Hanks
Karen L. Hanks, Esq.
Nevada Bar No. 9578
7625 Dean Martin Drive, Ste 110
Las Vegas, Nevada 89139
Attorneys for Plaintiff Hillcrest Investments,
Ltd.

/s/ Debbie Leonard
Debbie Leonard, Esq.
Nevada Bar No. 8260
955 South Virginia Street, Ste 220
Reno, Nevada 89502
Attorney for American Borate Company and
American Borate Company of Texas

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LAW OFFICES OF BYRON THOMAS

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/s/ Byron Thomas
Bryon Thomas, Esq.
Nevada Bar No. 8906
3275 S. Jones Blvd. Ste 104
Las Vegas, Nevada 89146
Attorney for Amergosa Enterprise, LLC and
On behalf of himself individually

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IT IS SO ORDERED.

________________________________
U.S. DISTRICT COURT JUDGE
RICHARD
F. BOULWARE, II
UNITED STATES DISTRICT JUDGE
DATED this 21st day of November, 2022.

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