Le Petomane XXVII, Inc., not individually, but solely in its representative capacity as trustee of the Nevada Environmental Response Trust v. American Pacific Corporation

Filing 17

ORDER Granting #16 Stipulation for Extension of Time. American Pacific Corporation answer due 7/29/2021. Signed by Magistrate Judge Nancy J. Koppe on 7/14/2021. (Copies have been distributed pursuant to the NEF - JQC)

Case 2:21-cv-01166-APG-NJK Document 16 Filed 07/13/21 Page 1 of 3

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MICHAEL C. HETEY, ESQ.
Nevada Bar No. 5668
HAROLD J. ROSENTHAL, ESQ.
Nevada Bar No. 10208
THORNDAL ARMSTRONG DELK
BALKENBUSH & EISINGER
1100 East Bridger Avenue
Las Vegas, NV 89101-5315
Mail To:
P.O. Box 2070
Las Vegas, NV 89125-2070
Tel.: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Attorneys for Defendant,
AMERICAN PACIFIC CORPORATION
UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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LE PETOMANE XXVII, INC., an Illinois
corporation, not individually, but solely in its
representative capacity as trustee of the Nevada
Environmental Response Trust,

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Case No. 2:21-cv-01166-APG-NJK
STIPULATION AND ORDER FOR
EXTENSION OF TIME FOR
DEFENDANT AMERICAN PACIFIC
CORPORATION TO RESPOND TO
PLAINTIFF’S COMPLAINT (FIRST
REQUEST)

Plaintiff,

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vs.

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AMERICAN PACIFIC CORPORATION, a
Nevada corporation,

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Defendant.
STIPULATION AND ORDER FOR EXTENSION OF TIME FOR DEFENDANT
AMERICAN PACIFIC CORPORATION TO RESPOND TO PLAINTIFF’S
COMPLAINT (FIRST REQUEST)

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This is the First Request to extend the time for Defendant to respond to Plaintiff’s

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Complaint. Defendant, American Pacific Corporation (“Defendant”), by and through its counsel,

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Thorndal Armstrong Delk Balkenbush & Eisinger, and Plaintiff, Le Petomane XXVII, Inc. solely

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in its representative capacity as trustee of the Nevada Environmental Response Trust

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(“Plaintiff”), by and through its counsel, Fennemore Craig, P.C. and Foley & Lardner LLP (Pro

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Hac Vice), hereby stipulate to allow Defendant a two (2) week extension to respond to Plaintiff’s

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Case 2:21-cv-01166-APG-NJK Document 16 Filed 07/13/21 Page 2 of 3

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Complaint. Plaintiff filed its Complaint on June 21, 2021 and served Defendant with its

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Complaint on June 24, 2021 making the current due date July 15, 2021. Plaintiff and Defendant

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submitted a stipulation to the Court on July 12, 2021, stipulating to a two (2) week extension of

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time to file a responsive pleading extending the time to July 29, 2021, but the stipulation was

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denied without prejudice by the Court on July 13, 2021, citing a request for additional

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information and compliance with Local Rule IA 6-1(a).

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Pursuant to Local Rule IA 6-1(a), the basis for this first request stipulation for an

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additional two-week time period to prepare and file a responsive pleading to Plaintiff’s

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Complaint, is that Defendant is engaging additional counsel who will be joining the defense.

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The additional counsel require the additional requested two (2) week time period to July 29,

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Case 2:21-cv-01166-APG-NJK Document 16 Filed 07/13/21 Page 3 of 3

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2021, to assist with preparation of responsive pleadings. Said counsel will be applying for Pro

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Hac status in the near future as well.

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Based upon the foregoing, Plaintiff and Defendant herby stipulate that Defendant may
file and serve its responsive pleading on or before July 29, 2021.
Dated this 13th day of July 2021.

Dated this 13th day of July 2021.

FENNEMORE CRAIG, P.C.

THORNDAL ARMSTRONG DELK
BALKENBUSH & EISINGER

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/s/ Josh Reid

/s/ Michael C. Hetey

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JOSH REID, ESQ.
Nevada Bar No. 7497
300 South 4th Street, Suite 1400
Las Vegas, Nevada 89101

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(Pro Hac Vice)
ERIC L. MAASSEN, ESQ.
WILLIAM J. MCKENNA, ESQ.
TANYA C. O’NEILL, ESQ.
FOLEY & LARDNER LLP
777 East Wisconsin Avenue
Milwaukee, Wisconsin 53202
Attorneys for Plaintiff,
LE PETOMANE XXVII, INC. solely in its
representative capacity as trustee of the
NEVADA ENVIRONMENTAL RESPONSE
TRUST

MICHAEL C. HETEY, ESQ.
Nevada Bar No. 5668
HARRY J. ROSENTHAL, ESQ.
Nevada bar No. 10208
1100 East Bridger Avenue
Las Vegas, Nevada 89101
Attorneys for Defendant,
AMERICAN PACIFIC CORPORATION, a
Nevada corporation

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ORDER
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IT IS SO ORDERED.
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Dated: July 14, 2021
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UNITED STATES MAGISTRATE JUDGE

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