Zuniga v. Unforgettable Coatings Inc et al

Filing 14

ORDER Granting 13 Stipulation for Extension of Time re Complaint re 1 Petition for Removal (Fourth Request). Defendants answer due 10/7/2021. Signed by Magistrate Judge Cam Ferenbach on 9/9/2021. (Copies have been distributed pursuant to the NEF - MR)

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Case 2:21-cv-01221-JCM-VCF Document 14 Filed 09/09/21 Page 1 of 2 1 2 3 4 5 6 7 8 Paul T. Trimmer Nevada State Bar No. 9291 Holly E. Walker Nevada State Bar No. 14295 JACKSON LEWIS P.C. 300 S. Fourth Street, Suite 900 Las Vegas, Nevada 89101 Tel: (702) 921-2460 Fax: (702) 921-2461 Email: paul.trimmer@jacksonlewis.com Email: holly.walker@jacksonlewis.com Attorneys for Defendants Unforgettable Coatings, Inc.; Unforgettable Coatings of Idaho LLC 9 UNITED STATES DISTRICT COURT 10 DISTRICT OF NEVADA 11 JOSE ISMAEL ZUNIGA, on behalf of himself and all others similarly situated, 12 13 14 15 Case No.: 2:21-cv-01221-JCM-VCF Plaintiff, STIPULATION TO EXTEND DEADLINE FOR DEFENDANTS TO RESPOND TO PLAINTIFF’S COMPLAINT vs. UNFORGETTABLE COATINGS INC,; UNFORGETTABLE COATINGS OF IDAHO LLC; DOES 1 through 50; inclusive. 16 (FOURTH REQUEST) Defendants. 17 18 IT IS HEREBY STIPULATED by and between Plaintiff Jose Ismael Zuniga, (“Plaintiff”), 19 through his counsel, Gabroy Law Offices, and Defendants, Unforgettable Coatings, Inc. and 20 Unforgettable Coatings of Idaho, LLC, (“Defendants”), by and through their counsel, Jackson 21 Lewis P.C., that Defendants shall have an extension up to and including October 7, 2021, in 22 which to file their respective responses to Plaintiff’s Complaint. This Stipulation is submitted and 23 based upon the following: 24 1. Plaintiff filed his Complaint on May 25, 2021 in the Eighth Judicial District Court 25 of Clark County, Nevada, Case No. A-21-835257-C. The Summons and Complaint were served 26 on or about June 8, 2021. 27 28 Jackson Lewis P.C. Las Vegas 2. Defendants’ filed their Petition for Removal of Civil Action from State Court on June 29, 2021. 1 Case 2:21-cv-01221-JCM-VCF Document 14 Filed 09/09/21 Page 2 of 2 1 3. Defendants’ Answer is currently due September 7, 2021. 2 4. This is the fourth request for an extension of time for Defendants to file a response 3 4 5 to Plaintiff’s Complaint. 5. The parties are discussing a potential resolution of Plaintiff’s claims, which would render any such response unnecessary. 6 6. This request is made in good faith and not for the purpose of delay. 7 7. Nothing in this Stipulation, nor the fact of entering to the same, shall be construed 8 as waiving any claim and/or defense held by any party. 9 Dated this 2nd day of September, 2021. GABROY LAW OFFICES JACKSON LEWIS P.C. /s/ Holly E. Walker Paul T. Trimmer, State Bar No. 9291 Holly E. Walker, State Bar No. 14295 300 S. Fourth Street, Suite 900 Las Vegas, Nevada 89101 14 /s/ Christian Gabroy Christian Gabroy, State Bar No. 8805 Kaine Messer, State Bar No. 14240 Dominique Bosa-Edwards, State Bar No. 15705 170 S. Green Valley Pkwy., Suite 280 Henderson, NV 89012 15 Attorneys for Plaintiff 10 11 12 13 Attorneys for Defendants 16 17 ORDER 18 IT IS SO ORDERED. 19 20 U.S. Magistrate Judge 21 Dated: 9-9-2021 22 23 24 25 26 27 28 Jackson Lewis P.C. Las Vegas 2

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