MJL 12, LLC v. MJJ Productions, LLC et al

Filing 23

ORDER Granting 22 Stipulation for Extension of TIme 13 Motion to Dismiss. Responses due by 5/17/2024. Signed by Judge Gloria M. Navarro on 5/9/2024. (Copies have been distributed pursuant to the NEF - ALZ)

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W. West Allen, Esq.
Nevada Bar No. 5566
Jonathan W. Fountain, Esq.
Nevada Bar No. 10351
HOWARD & HOWARD ATTORNEYS PLLC
3800 Howard Hughes Parkway, Suite 1000
Las Vegas, Nevada 89169
Telephone: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Plaintiff MJL 12, LLC

HOWARD & HOWARD ATTORNEYS PLLC

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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MJL 12, LLC, a Nevada limited liability
company,

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v.

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Case No. 2:24-cv-00122-GMN-EJY
STIPULATION AND [PROPOSED]
ORDER EXTENDING THE TIME
FOR PLAINTIFF TO FILE AND SERVE
ITS RESPONSE TO DEFENDANT’S
MOTION TO DISMISS

Plaintiff,

TRIUMPH INTERNATIONAL, LLC, a
California limited liability company,

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(First Request)

Defendant.

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Pursuant to Federal Rule of Civil Procedure 6(b) and LR IA 6-1, the parties, by and

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through their undersigned counsel, hereby agree and stipulate to extend the date for Plaintiff MJL

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12, LLC to file and serve its response to Defendant Triumph International, LLC’s Special Motion

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to Dismiss Plaintiff’s Seventh Claim Pursuant to Nevada Anti-SLAPP Statute; and Motion to

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Dismiss Sixth and Seventh Claims Pursuant to Fed. R. Civ. P. 12(b)(6) and Second Claim

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Pursuant to Fed. R. Civ. P. 12(b)(1) and 12(b)(6) (ECF No. 13), filed on April 26, 2024

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(hereinafter, the “Motion”), and, in support of the same, state the following:
1.

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Plaintiff filed its Complaint for Declaratory and Other Relief on January 17, 2024.

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(ECF No. 1.) On February 26, 2024, Plaintiff sent Defendant a request to waive formal service of

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the Summons and Complaint. (ECF No. 7.) Defendant executed the waiver on March 11, 2024.

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(Id.) As a result, Defendant’s answer or other response to the Complaint was due on April 26,

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2024. (Id.)

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2.

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seventh claim for relief pursuant to Nevada’s Anti-SLAPP statute and seeking to dismiss

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Plaintiff’s sixth and seventh claims pursuant to Rule 12(b)(1) and 12(b)(6) of the Federal Rules of

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Civil Procedure.

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3.

Plaintiff has requested, and Defendant has agreed, that Plaintiff may have until

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May 17, 2024 to respond to the Motion in order to accommodate the schedules of Plaintiff’s

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counsel.
4.

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HOWARD & HOWARD ATTORNEYS PLLC

On April 26, 2024, Defendant filed the Motion seeking to dismiss Plaintiff’s

response to the Motion from May 10, 2024, to May 17, 2024.
5.

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The parties therefore agree to extend the date for Plaintiff to file and serve its

This is the first request for an extension of time to respond to the Motion.

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