Philadelphia Indemnity Insurance Company v. Vintage, Inc. et al

Filing 15

ORDER granting 14 Stipulation. The deadline for Defendants to file a response to Plaintiff's Motion for Preliminary Injunction (ECF No. 3 ) and Temporary Restraining Order (ECF NO. 4 ) is extended until January 30, 2025. Signed by Judge Richard F. Boulware, II on 1/5/2025. (Copies have been distributed pursuant to the NEF - DLS)

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Attorneys for Defendants
VINTAGE, INC. dba VINTAGE POOLS and
SARAH JACKSON

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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THE WRIGHT LAW GROUP P.C.
2340 Paseo Del Prado, Suite D-305
Las Vegas, Nevada 89102
Tel: [phone] Fax: [phone]

JOHN HENRY WRIGHT, ESQ.
Nevada Bar No. 6182
THE WRIGHT LAW GROUP, P.C.
2340 Paseo Del Prado, Suite D-305
Las Vegas, Nevada 89102
Telephone: [phone]
Email: [e-mail]

Plaintiff,

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vs.

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VINTAGE, INC. dba VINTAGE POOLS;
SARAH JACKSON; and DOES 1 through
X, and ROE CORPORATIONS, 1 through
X, inclusive,

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CASE NO. 2:24-cv-1828

PHILADELPHIA INDEMNITY
INSURANCE COMPANY,

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STIPULATION AND ORDER TO
EXTEND DEADLINE FOR
DEFENDANTS VINTAGE, INC. dba
VINTAGE POOLS and SARAH
JACKSON TO FILE RESPONSE TO
PLAINTIFF’S MOTION FOR
PRELIMINARY INJUNCTION (ECF #3)
AND TEMPORARY RESTRAINING
ORDER (ECF #4)

Defendants.

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(SECOND REQUEST)

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COME NOW, Defendants VINTAGE, INC. dba VINTAGE POOLS and SARAH

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JACKSON(“Defendants””) by and through their counsel of record, John Henry Wright, Esq., of

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The Wright Law Group, P.C., and Plaintiff PHILADELPHIA INDEMNITY INSURANCE

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COMPANY(“PIIC”) by and through its attorney, Kurt C. Faux, Esq., of The Faux Law Group, and

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hereby stipulate and agree as follows:

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PIIC filed its Complaint (ECF # 1), Motion for Preliminary Injunction (ECF #3) and

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Temporary Restraining Order (ECF #4) on September 30, 2024. On October 8, 2024 Defendants

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were served with the Summons and Complaint (ECF # 9). On November 26, 2024 the Court

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issued a Minute Order (ECF #10) directing the Defendants to file their response to Plaintiff’s

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Motion for Preliminary Injunction (ECF #3) and Temporary Restraining Order (ECF #4) by

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December 10, 2024.
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THE WRIGHT LAW GROUP P.C.
2340 Paseo Del Prado, Suite D-305
Las Vegas, Nevada 89102
Tel: [phone] Fax: [phone]

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The parties are currently negotiating and the underlying state lawsuit has been settled

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pending finalization of the settlement agreement currently with counsel for plaintiff in the

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underlying state case and Mr. Faux. Defendants have already partially performed under the terms

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of settlement agreement.

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Therefore, the parties to the instant case hereby agree and request the Court’s consent to

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extend the current deadline to oppose Plaintiff’s Motion for Preliminary Injunction (ECF #3) and

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Temporary Restraining Order (ECF #4) by thirty days along with a continuation of the deadline set

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by the Court in its November 26, 2024 Minute Order.

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IT IS HEREBY AGREED AND STIPULATED, that the deadline for Defendants to file

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a response to Plaintiff’s Motion for Preliminary Injunction (ECF #3) and Temporary Restraining

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Order (ECF #4) shall be extended until January 30, 2025.

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The parties have entered into the agreement and good faith and not for any improper
purpose or delay. This is the parties’ second request for an extension.

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Dated this 3rd day of January, 2025.

Dated this 3rd day of January, 2025.

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THE FAUX LAW GROUP

THE WRIGHT LAW GROUP, P.C.

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/s/ Kurt C. Faux, Esq.

/s/ John Henry Wright, Esq.

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Kurt C. Faux, Esq.
Nevada Bar No. 003407
Willi H. Siepmann, Esq.
Nevada Bar No. 002478
2625 N. Green Valley Pkwy., Suite 100
Henderson, NV 89014

JOHN HENRY WRIGHT, ESQ.
Nevada Bar No. 6182
2340 Paseo Del Prado, Ste. D-305
Las Vegas, Nevada 89102

Attorneys for Defendants
VINTAGE, INC. dba VINTAGE POOLS and
SARAH JACKSON

Attorneys for Plaintiff PHILADELPHIA
INDEMNITY INSURANCE COMPANY

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IT IS SO ORDERED.
________________________________________
RICHARD F. BOULWARE, II
UNITED STATES DISTRICT JUDGE
DATED this 5th of January 2025.
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