Zuniga v. Unforgettable Coatings Inc et al
Filing
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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)
Case 2:21-cv-01221-JCM-VCF Document 14 Filed 09/09/21 Page 1 of 2
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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
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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JOSE ISMAEL ZUNIGA, on behalf of himself
and all others similarly situated,
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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.
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(FOURTH REQUEST)
Defendants.
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IT IS HEREBY STIPULATED by and between Plaintiff Jose Ismael Zuniga, (“Plaintiff”),
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through his counsel, Gabroy Law Offices, and Defendants, Unforgettable Coatings, Inc. and
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Unforgettable Coatings of Idaho, LLC, (“Defendants”), by and through their counsel, Jackson
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Lewis P.C., that Defendants shall have an extension up to and including October 7, 2021, in
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which to file their respective responses to Plaintiff’s Complaint. This Stipulation is submitted and
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based upon the following:
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1.
Plaintiff filed his Complaint on May 25, 2021 in the Eighth Judicial District Court
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of Clark County, Nevada, Case No. A-21-835257-C. The Summons and Complaint were served
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on or about June 8, 2021.
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Jackson Lewis P.C.
Las Vegas
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Defendants’ filed their Petition for Removal of Civil Action from State Court on
June 29, 2021.
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Case 2:21-cv-01221-JCM-VCF Document 14 Filed 09/09/21 Page 2 of 2
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3.
Defendants’ Answer is currently due September 7, 2021.
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This is the fourth request for an extension of time for Defendants to file a response
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to Plaintiff’s Complaint.
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The parties are discussing a potential resolution of Plaintiff’s claims, which would
render any such response unnecessary.
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This request is made in good faith and not for the purpose of delay.
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Nothing in this Stipulation, nor the fact of entering to the same, shall be construed
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as waiving any claim and/or defense held by any party.
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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
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/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
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Attorneys for Plaintiff
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Attorneys for Defendants
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ORDER
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IT IS SO ORDERED.
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U.S. Magistrate Judge
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Dated: 9-9-2021
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Jackson Lewis P.C.
Las Vegas
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