Underhill v. For The Earth Corporation et al

Filing 6

ORDER Granting #5 Stipulation for Extension of Time. For The Earth Corporation and Nelson Grist answer due 7/28/2021. Signed by Magistrate Judge Cam Ferenbach on 7/15/2021. (Copies have been distributed pursuant to the NEF - JQC)

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JOSHUA A. SLIKER, ESQ.
Nevada Bar No. 12493
HOLLY E. WALKER, ESQ.
Nevada Bar No. 14295
JACKSON LEWIS P.C.
300 S. Fourth Street, Suite 900
Las Vegas, Nevada 89101
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendants
For The Earth Corporation,
and Nelson Grist

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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FRANK UNDERHILL, JR., an individual,
Plaintiff,

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STIPULATION TO EXTEND
DEADLINE FOR DEFENDANTS TO
RESPOND TO PLAINTIFF’S
COMPLAINT

vs.

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Case No.: 2:21-cv-01287-VCF

FOR THE EARTH CORPORATION, an
Arizona Corporation; NELSON GRIST, an
individual; DOES I through X, inclusive; and
ROE ENTITIES XI through M, inclusive,

(FIRST REQUEST)

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Defendant.

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IT IS HEREBY STIPULATED by and between Plaintiff Frank Underhill Jr., (“Plaintiff”),

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through his counsel EAD Law Group, LLC, and Defendants Integrity Health Corporation f/k/a For

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The Earth Corporation and Nelson Grist (“Defendants”), through their counsel Jackson Lewis P.C.,

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that Defendants shall have a 14-day extension up to and including Wednesday, July 28, 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.

Defendants’ respective responses to Plaintiff’s Complaint are currently due on July

14, 2021.

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JACKSON LEWIS P.C
LAS VEGAS

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2.

Due to defense counsel’s recent retention, Defendants require additional time to

investigate Plaintiff’s allegations before responding to the Complaint.
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This is the first request for an extension of time for Defendants to file responses to

Plaintiff’s Complaint.

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4.

This request is made in good faith and not for the purpose of delay.

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5.

Nothing in this Stipulation, nor the fact of entering into the same, shall have the

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effect of or be construed as waiving any claim or defense held by any party hereto.
Dated this 14th day of July, 2021.
EAD LAW GROUP, LLC

JACKSON LEWIS P.C.

/s/ Elaine Dowling
ELAINE DOWLING, ESQ.
Nevada Bar No. 8051
8275 S. Eastern Avenue, Suite 200
Las Vegas, Nevada 89123

/s/ Joshua A. Sliker
JOSHUA A. SLIKER, ESQ.
Nevada Bar No. 12493
300 South Fourth Street, Suite 900
Las Vegas, Nevada 89101

Attorney for Plaintiff
Frank Underhill, Jr.

Attorneys for Defendants
For The Earth Corporation,
and Nelson Grist

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ORDER

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IT IS SO ORDERED:

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United States Magistrate Judge
7-15-2021
Dated: _________________________

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JACKSON LEWIS P.C
LAS VEGAS

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