Oswell v. Precision Valve, Inc.

Filing 14

ORDER granting 12 Stipulation; Precision Valve, Inc. answer due 1/7/2022. Signed by Magistrate Judge Daniel J. Albregts on 1/7/2022. (Copies have been distributed pursuant to the NEF - HAM)

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Case 2:21-cv-02173-APG-DJA Document 12 Filed 01/06/22 Page 1 of 3 14 01/07/22 1 2 3 4 5 6 7 8 S. BRETT SUTTON Nevada Bar No. 12109 JARED HAGUE Nevada Bar No. 12761 JOSE CARMONA Nevada Bar No. 14494 SUTTON HAGUE LAW CORPORATION, P.C. 5200 N. Palm Avenue, Suite 203 Fresno, California 93704 Telephone: (559) 325-0500 Facsimile: (559) 981-1217 brett@suttonhague.com jared@suttonhague.com jose@suttonhague.com 9 Attorneys for Defendant: Precision Valve, Inc. 10 UNITED STATES DISTRICT COURT 11 DISTRICT OF NEVADA 12 SOUTHERN DIVISION * * * 13 14 15 MICHAEL OSWELL, an individual, 16 PLAINTIFF, 17 18 19 20 21 vs. PRECISION VALVE, INC., a Nevada corporation; DOES I through X, and ROE Corporations XI through XX, inclusive, Case No.: 2:21-CV-02173-APG-DJA STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE DEFENDANT’S ANSWER Removal Date: December 9, 2021 Trial Date: Non Set DEFENDANTS. 22 23 Plaintiff Michael Oswell (hereinafter “Plaintiff”) and Defendant Precision Valve, Inc. 24 (“Defendant”) (collectively “the Parties”), by and through their attorneys of record, hereby submit the 25 following Stipulation and [Proposed] Order granting leave to Defendant to file its Answer to Plaintiff’s 26 First Amended Complaint. 27 WHEREAS, Plaintiff filed his Complaint in the Eighth Judicial District Court for Clark County, 28 State of Nevada on September 20, 2021. 1 STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE DEFENDANT’S ANSWER Case 2:21-cv-02173-APG-DJA Document 12 Filed 01/06/22 Page 2 of 3 14 01/07/22 1 WHEREAS, Plaintiff served Defendant with the Complaint on November 12, 2021. 2 WHEREAS, Plaintiff filed his First Amended Complaint in the Eighth Judicial District Court for 3 Clark County, State of Nevada on November 22, 2021. 4 WHEREAS, Plaintiff filed proof of service for the First Amended Complaint with a service date 5 of November 23, 2021. 6 WHEREAS, Defendant has no record of being served on that date, but is not contesting service of 7 the First Amended Complaint. 8 WHERAS, Defendant timely removed this matter to the Instant Court on December 9, 2021. 9 WHEREAS, the Parties respectfully request that the Court refrain from entering an Order of 10 Default against Defendant, and therefore: 11 IT IS HEREBY STIPUALTED AND AGREED, that Defendant shall have until January 7, 2022 12 to file its Answer to the First Amended Complaint. 13 IT IS FURTHER STIPULATED AND AGREED, that Defendant can file its Answer to Plaintiff’s 14 First Amended Complaint on or before January 7, 2022. 15 Dated: January 6, 2022 SUTTON HAGUE LAW CORPORATION, P.C. 16 17 By: 18 19 20 21 Dated: January 6, 2022 ____________ S. BRETT SUTTON JARED HAGUE JOSE CARMONA Attorneys for Defendant, Precision Valve, Inc. GABROY LAW OFFICES 22 23 24 25 26 By: _/s/ Kaine Messer CHRISTIAN GABROY KAINE MESSER Attorneys for Plaintiff, Michael Oswell 27 28 2 STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE DEFENDANT’S ANSWER Case 2:21-cv-02173-APG-DJA Document 12 Filed 01/06/22 Page 3 of 3 14 01/07/22 1 2 ORDER GRANTING DEFENDANT LEAVE TO FILE ITS ANSWER IT IS ORDERED, ADJUDGED AND DECREED, that Defendant shall have until January 7, 2022 3 to file its Answer to the First Amended Complaint. 4 5 7 ____________________________________________ UNITED STATES DISTRICT JUDGE DANIEL J. ALBREGTS UNITED STATES MAGISTRATE JUDGE 8 January 7, 2022 DATED: ________________________________ 6 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 3 STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE DEFENDANT’S ANSWER

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