Aim High Investment Group LLC v. Spectrum Laboratories, LLC

Filing 49

ORDER granting 46 Motion to Extend Time Re: 42 Motion to Strike, 45 Motion to Compel. Responses due by 1/27/2023. Signed by Magistrate Judge Daniel J. Albregts on 1/17/2023. (Copies have been distributed pursuant to the NEF - HAM)

Case 2:22-cv-00158-GMN-DJA Document 49
46 Filed 01/17/23
01/12/23 Page 1 of 3

1 NICHOLAS J. SANTORO (NBN. 532)
JASON D. SMITH (NBN 9691)
2 SANTORO WHITMIRE, LTD.
10100 W. Charleston Blvd., Suite 250
3 Las Vegas, Nevada 89135
Telephone: [phone]
4 Facsimile: [phone]
E-mail: [e-mail]; [e-mail]
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DAVID B. CUPAR (Admitted Pro Hac Vice)
6 MATTHEW J. CAVANAGH (Admitted Pro Hac Vice)
MCDONALD HOPKINS LLC
7 600 Superior Avenue East, Suite 2100
Cleveland, OH 44114
8 Telephone: [phone]
Facsimile: [phone]
9 E-Mail: [e-mail], [e-mail]
10 Attorneys for Defendant and Counterclaimant
SPECTRUM LABORATORIES, LLC
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UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF NEVADA
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13 AIM HIGH INVESTMENT GROUP, LLC,
Plaintiff/Counter-Defendant,

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16 SPECTRUM LABORATORIES, LLC
Defendant/Counterclaimant.

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Case No.

2:22-cv-00158-GMN-DJA

JOINT MOTION FOR EXTENSION OF
TIME TO RESPOND
(First Request)

The Parties jointly move to extend their briefing deadlines related to two Aim High motions:
Aim High’s Motion to Strike (ECF #24) and Motion to Compel (ECF #25) as follows:
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Spectrum moves to have its January 13, 2023 deadline related to Aim High’s Motion to
Compel by two weeks to noon (12:00 p.m.) Eastern Time on January 27, 2023.



Aim High moves to have its reply deadlines moved by one week: January 27 for its reply to
Spectrum’s opposition to its Motion to Strike (ECF #24) and (should the Court grant
Spectrum’s motion to extend) February 10 for its reply to Spectrum’s opposition to its Motion
to Compel (ECF #25).
This is the first request for extensions of time sought by the parties with respect to each of

these deadlines. Good cause exists for these extensions. The additional two weeks allows Spectrum

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and its attorneys to investigate Aim High’s motion to compel to minimize any issues and prepare a
response, if needed, that addresses only what issues remain. Also, good cause exists because Aim
High served additional discovery on December 18, 2022 that are due by January 17, 2023, for which
Spectrum did not have sufficient time to address the above due to the Christmas and New Year’s
holidays and numerous conflicting schedules during that time. Further, Spectrum’s counsel also has
had complex Federal Circuit appeal and District Court briefing that took a substantial amount of time
to complete. In fairness, Spectrum agreed to allow Aim High additional time to respond to its
oppositions to avoid prejudice on any party or counsel.
This extension is not at all sought for delay or for any other improper purpose, but rather is
requested due to a genuine need for more time. Plaintiff Aim High consents to the motion, and no
other deadlines will be impacted, no party would be prejudiced by the granting of it. Therefore, the
Court should grant this motion and allow the extensions listed above.

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Dated: January 12, 2023
/s/ Ryan Gile (by consent)
RYAN GILE, ESQ. (NBN 8807)
GILE LAW GROUP LTD.
1180 N. Town Center Drive, Suite 100
Las Vegas, NV 89144
Tel. [phone]
Email: [e-mail]
JAMES K. CLELAND
(Admitted Pro Hac Vice)
DICKINSON WRIGHT PLLC
350 S. Main Street, Suite 300
Ann Arbor, MI 48104,
[e-mail]
Tel: [phone]

Respectfully submitted,
/s/ David B. Cupar
David B. Cupar (admitted pro hac vice)
Matthew J. Cavanagh (admitted pro hac vice)
MCDONALD HOPKINS LLC
600 Superior Avenue, East, Ste. 2100
Cleveland, Ohio 44114
t 216-348-5400│f 216-348-5474
[e-mail]
[e-mail]
NICHOLAS J. SANTORO
Nev. Bar No. 532
JASON D. SMITH, ESQ.
Nev. Bar. No. 9691
SANTORO WHITMIRE, LTD.
10100 W. Charleston Blvd., Suite 250
Las Vegas, Nevada 89135
Telephone: [phone]
Facsimile: [phone]
E-mail: [e-mail]
E-mail: [e-mail]

FRANKLIN M. SMITH
(Admitted Pro Hac Vice)
DICKINSON WRIGHT PLLC
2600 W. Big Beaver Rd, Suite 300
Attorneys for Spectrum Laboratories, LLC
Troy, Michigan 48084
[e-mail],
Tel: [phone]
Attorneys for Plaintiff/Counter-Defendant

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IT IS SO ORDERED:

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UNITED STATES MAGISTRATE JUDGE

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DATED: 1/17/2023

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