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)

Case 2:21-cv-02173-APG-DJA Document 12 Filed 01/06/22 Page 1 of 3
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01/07/22

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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: [phone]
Facsimile: [phone]
[e-mail]
[e-mail]
[e-mail]

9 Attorneys for Defendant: Precision Valve, Inc.
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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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SOUTHERN DIVISION
* * *

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MICHAEL OSWELL, an individual,

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PLAINTIFF,

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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.

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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.
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WHEREAS, Plaintiff filed his Complaint in the Eighth Judicial District Court for Clark County,

28 State of Nevada on September 20, 2021.
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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
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WHEREAS, Plaintiff served Defendant with the Complaint on November 12, 2021.

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WHEREAS, Plaintiff filed his First Amended Complaint in the Eighth Judicial District Court for

3 Clark County, State of Nevada on November 22, 2021.
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WHEREAS, Plaintiff filed proof of service for the First Amended Complaint with a service date

5 of November 23, 2021.
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WHEREAS, Defendant has no record of being served on that date, but is not contesting service of

7 the First Amended Complaint.
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WHERAS, Defendant timely removed this matter to the Instant Court on December 9, 2021.

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WHEREAS, the Parties respectfully request that the Court refrain from entering an Order of

10 Default against Defendant, and therefore:
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IT IS HEREBY STIPUALTED AND AGREED, that Defendant shall have until January 7, 2022

12 to file its Answer to the First Amended Complaint.
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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.
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SUTTON HAGUE LAW CORPORATION, P.C.

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By:

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Dated: January 6, 2022

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S. BRETT SUTTON
JARED HAGUE
JOSE CARMONA
Attorneys for Defendant,
Precision Valve, Inc.

GABROY LAW OFFICES

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By:

_/s/ Kaine Messer
CHRISTIAN GABROY
KAINE MESSER
Attorneys for Plaintiff,
Michael Oswell

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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
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01/07/22

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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.
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____________________________________________
UNITED STATES DISTRICT JUDGE
DANIEL J. ALBREGTS
UNITED STATES MAGISTRATE JUDGE

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January 7, 2022
DATED: ________________________________

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STIPULATION AND [PROPOSED] ORDER FOR LEAVE TO FILE DEFENDANT’S ANSWER