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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1 2 3 4 5 6 7 8 9 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: (702) 921-2460 Facsimile: (702) 921-2461 Email: joshua.sliker@jacksonlewis.com Email: holly.walker@jacksonlewis.com Attorneys for Defendants For The Earth Corporation, and Nelson Grist 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 13 FRANK UNDERHILL, JR., an individual, Plaintiff, 14 17 STIPULATION TO EXTEND DEADLINE FOR DEFENDANTS TO RESPOND TO PLAINTIFF’S COMPLAINT vs. 15 16 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) 18 Defendant. 19 20 IT IS HEREBY STIPULATED by and between Plaintiff Frank Underhill Jr., (“Plaintiff”), 21 through his counsel EAD Law Group, LLC, and Defendants Integrity Health Corporation f/k/a For 22 The Earth Corporation and Nelson Grist (“Defendants”), through their counsel Jackson Lewis P.C., 23 that Defendants shall have a 14-day extension up to and including Wednesday, July 28, 2021, in 24 which to file their respective responses to Plaintiff’s Complaint. This Stipulation is submitted and 25 based upon the following: 26 27 1. Defendants’ respective responses to Plaintiff’s Complaint are currently due on July 14, 2021. 28 JACKSON LEWIS P.C LAS VEGAS 1 1 2 3 4 2. Due to defense counsel’s recent retention, Defendants require additional time to investigate Plaintiff’s allegations before responding to the Complaint. 3. This is the first request for an extension of time for Defendants to file responses to Plaintiff’s Complaint. 5 4. This request is made in good faith and not for the purpose of delay. 6 5. Nothing in this Stipulation, nor the fact of entering into the same, shall have the 7 8 9 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 10 11 12 13 14 15 16 17 ORDER 18 IT IS SO ORDERED: 19 20 21 22 United States Magistrate Judge 7-15-2021 Dated: _________________________ 23 24 25 26 27 28 JACKSON LEWIS P.C LAS VEGAS 2

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