Navarrette v. Ntooitive Digital, LLC

Filing 8

ORDER granting 7 Stipulation. Response/Answer due by December 6, 2024. Signed by Magistrate Judge Daniel J. Albregts on 11/25/2024. (Copies have been distributed pursuant to the NEF - DLS)

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DEVERIE J. CHRISTENSEN, ESQ.
Nevada State Bar No. 6596
JACKSON LEWIS P.C.
300 S. Fourth Street, Suite 900
Las Vegas, Nevada 89101
Tel: [phone]
Email: [e-mail]
VICTOR N. CORPUZ, ESQ. (Pro Hac Vice Pending)
KELSEY R. SHERMAN, ESQ. (Pro Hac Vice Pending)
500 North Akard Street, Suite 2500
Dallas, Texas 75201
Tel: [phone]
Email: [e-mail]
Email: [e-mail]
Attorneys for Defendants
Ntooitive Digital, LLC, Vikas
Khorana, and Brian Johnson

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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ROWENA NAVARRETTE, an individual,

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Plaintiff,

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vs.
NTOOITIVE DIGITAL, LLC, a domestic
limited-liability company, VIKAS KHORANA,
an individual, BRIAN JOHNSON, an
individual, DOES 1-20, inclusive,

Case No. 2:24-cv-02136-RFB-DJA
STIPULATION AND ORDER TO
EXTEND DEADLINE FOR
DEFENDANTS TO RESPOND TO
PLAINTIFF’S COMPLAINT
(FIRST REQUEST)

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Defendant.

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IT IS HEREBY STIPULATED by and between Plaintiff Rowena Navarrette, (“Plaintiff”),

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by and through her counsel, the Bourassa Law Group, and Defendants, Ntooitive Digital, LLC,

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Vikas Khorana and Brian Johnson (“Defendants”), by and through their counsel, the law firm of

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Jackson Lewis P.C., that Defendants shall have an extension up to and including December 6, 2024,

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in which to file their responses to Plaintiff’s Complaint. This Stipulation is submitted and based

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upon the following:

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1.

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Jackson Lewis P.C.
Las Vegas

Plaintiff filed her Complaint on October 21, 2024 in the District Court, Clark County

Nevada, Case No. A-24-904336-C. The Summons and Complaint were served on Defendants

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Ntooitive Digital, LLC and Vikas Khorana on or about October 25, 2024, and on Defendant Brian

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Johnson on or about November 1, 2024.
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On November 15, 2024, the Defendants filed a Notice to Federal Court of Removal

of Civil Action from State Court, Case No. 2:24-cv-02136-RFB-DJA.
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Undersigned Defense Counsel has been unable to complete draft responses for all

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the Defendants as Counsel became unexpectedly ill with the flu on November 5, 2025, and was out

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of the office for over a week due to illness and was unable to work on the responses during that

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time. While Counsel had anticipated assistance from out of state colleagues, their Pro Hac Vice

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applications were delayed as the Court deferred a ruling on their applications requesting certain

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sections be completed or clarified by December 5, 2024. (ECF No. 6)
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Given Defense Counsels’ recent absence due to illness, and the time necessary to

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prepare responses to the Complaint, Defendants need additional time. Further, next week is the

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Thanksgiving Holiday when the parties and their counsels will be away with their families for the

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Holiday.

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5.

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Defendants to file responses to the Complaint.
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This is the first request for an extension of time for Defendants to file responses to

Plaintiff’s Complaint.
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Jackson Lewis P.C.
Las Vegas

Thus, the parties hereby stipulate to extend the deadline to December 6, 2024, for

This Stipulation is made in good faith and not for the purpose of delay.

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8.

Nothing in this Stipulation and Order shall operate to waive, relinquish, or impair

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any claim, defense, objection, or right of any party in this case. Further, nothing in this Stipulation

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and Order shall be construed as an admission of or consent to the merit or validity of any claim,

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defense, objection, or right by any party in this case.

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Dated this 22nd day of November, 2024.

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THE BOURASSA LAW GROUP

JACKSON LEWIS P.C.

/s/ Jennifer A. Fornetti
Mark J. Bourassa, Esq., NV Bar # 7999
Jennifer A. Fornetti, Esq., NV Bar #7644
Valerie S. Christian, Esq., NV Bar #14716
2350 W. Charleston Blvd., Suite 100
Las Vegas, Nevada 89102

/s/ Deverie J. Christensen
DEVERIE J. CHRISTENSEN, ESQ.
Nevada State Bar No. 6596
300 S. Fourth Street, Suite 900
Las Vegas, Nevada 89101
VICTOR N. CORPUZ, ESQ. (Pro Hac
Vice Pending)
KELSEY R. SHERMAN, ESQ. (Pro
Hac Vice Pending)
500 North Akard Street, Suite 2500
Dallas, Texas 75201

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Attorneys for Plaintiff
Rowena Navarrette

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Attorneys for Defendants
NTOOITIVE DIGITAL, LLC, Victor
Vikas and Brian Johnson

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ORDER

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IT IS SO ORDERED.

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United States Magistrate Judge

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Dated: 11/25/2024

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4880-7085-2863, v. 1

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Jackson Lewis P.C.
Las Vegas

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