Emulait, Inc. v. Roembke Turnkey Solutions, LLC et al

Filing 25

ORDER granting #24 Stipulation to Extend Time to Respond to Defendants' #17 Motion to Change Venue/Transfer and #16 Motion to Dismiss. Responses due by 2/11/2025. Signed by Chief Judge Andrew P. Gordon on 1/29/2025. (Copies have been distributed pursuant to the NEF - MAM)

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REX D. GARNER (SBN 9401)
[e-mail]
MARK J. CONNOT (SBN 010010)
[e-mail]
FOX ROTHSCHILD LLP
One Summerlin
1980 Festival Plaza Dr., Suite 700
Las Vegas, Nevada 89135
Telephone:
702.262.6899
Facsimile:
702.597.5503
BRETT A. BERMAN (PA BAR NO. 204843)
(Admitted Pro Hac Vice)
[e-mail]
FOX ROTHSCHILD LLP
2001 Market Street, Suite 1700
Philadelphia, PA 19103
[phone] (telephone)
[phone] (fax)
Attorneys for Plaintiff EMULAIT, INC. f/k/a
PROXAMAMA, INC.

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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EMULAIT, INC. f/k/a PROXAMAMA, INC.,

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Plaintiff,

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Case No. 2:24-CV-02267-APG-NJK

v.

STIPULATION AND ORDER TO
EXTEND DEADLINE TO RESPOND
TO DEFENDANTS’ MOTION TO
DISMISS OR TO TRANSFER

ROEMBKE TURNKEY SOLUTIONS, LLC,
ROEMBKE MFG. & DESIGN, INC., and
GREGORY J. ROEMBKE,

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(First Request)

Defendants.

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Pursuant to Local Rules IA 6-1, IA 6-2, and LR 7-1, Plaintiff Emulait, Inc. f/k/a

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Proxamama, Inc. (“Plaintiff”) and Defendants Roembke Turnkey Solutions, LLC, Roembke Mfg.

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& Design, Inc., and Gregory J. Roembke (“Defendants,” together with Plaintiff, the “Parties”),

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respectfully request that the Court approve this Stipulation to Extend the Deadline to Respond to

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Defendants’ Motion to Dismiss or to Transfer. This is the Parties’ first request.

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167502613.1

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IT IS HEREBY STIPULATED AND AGREED as follows:

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Defendants filed their Motion to Dismiss or to Transfer [ECF Nos. 16 and 17] (the

“Motion”) on January 17, 2025.

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2.

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January 31, 2025.

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3.

The current deadline for Plaintiff to file its response to Defendants’ Motion is

Defendants consent to a two-week extension on Plaintiff’s response deadline, as

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Defendants had also requested and were granted a two-week extension to file a response to the

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Complaint, which the Court approved [ECF No. 15].

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4.

Plaintiff requests the extension to permit sufficient time for Plaintiff and its

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employees to locate the documentation necessary to support the declaration it intends to file in

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support of its opposition to Defendants’ Motion to Dismiss or to Transfer.

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5.

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NOW, THEREFORE, IT IS HEREBY STIPULATED AND AGREED by and between

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the Parties that the time for Plaintiff to respond to Defendants’ Motion to Dismiss or to Transfer

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be extended to February 11, 2025.

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DATED this 28th day of January, 2025.

DATED this 28th day of January, 2025.

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FOX ROTHSCHILD LLP

KAEMPFER CROWELL

/s/ Rex D. Garner
REX D. GARNER (SBN 9401)
MARK J. CONNOT (SBN 010010)
BRETT A. BERMAN, ESQUIRE (PA BAR
NO. 204843) (Admitted Pro Hac Vice)
[e-mail]

/s/ Louis M. Bubala
LOUIS M. BUBALA III (SBN 8974)
KRIS KALKOWSKI (SBN 14892)

This request is not intended to cause delay or prejudice any party.

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Attorneys for Plaintiff EMULAIT, INC. f/k/a
PROXAMAMA, INC.

Attorneys for Defendants ROEMBKE
TURNKEY SOLUTIONS, LLC, ROEMBKE
MFG. & DESIGN, INC., and GREGORY J.
ROEMBKE

IT IS SO ORDERED:
January 29, 2025
Dated:__________________

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________________________
ANDREW P. GORDON
CHIEF UNITED STATES DISTRICT JUDGE

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167502613.1