Chemeon Surface Technology, LLC vs Metalast International, Inc, et al

Filing 435

ORDER granting ECF No. 434 Stipulation for Extension of Time to File Response to ECF No. 427 Motion for Summary Judgment. Response due by 9/10/2018. Signed by Judge Miranda M. Du on 9/10/2018. (Copies have been distributed pursuant to the NEF - KW)

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5441 Kietzke Lane, 2nd Floor
Reno, NV 89511
Phone: [phone] ♦ Fax: [phone]

HOLLAND & HART LLP

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Robert C. Ryan (#7164)
Timothy A. Lukas (#4678)
HOLLAND & HART LLP
5441 Kietzke Lane, Second Floor
Reno, Nevada 89511
Phone: [phone]
Fax: [phone]
[e-mail]
[e-mail]
Christopher B. Hadley
(Admitted pro hac vice)
JONES, WALDO, HOLBROOK & McDONOUGH, PC
1441 West Ute Blvd., Suite 330
Park City, Utah 84098
Telephone: [phone]
Facsimile: [phone]
[e-mail]
Attorneys for Plaintiff and Counter Defendants

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

14 CHEMEON SURFACE TECHNOLOGY, LLC, a
Nevada limited liability company,
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Plaintiff,
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v.
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METALAST INTERNATIONAL, INC., a Nevada
18 corporation; METALAST, INC., a Nevada
corporation; SIERRA DORADO, INC., a Nevada
19 corporation; DAVID M. SEMAS, an individual;
GREG D. SEMAS, an individual; and WENDI
20 SEMAS-FAURIA, an individual.
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Defendants.

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DAVID M. SEMAS; and METALAST
23 INTERNATIONAL, INC.,
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v.

Counterclaimants,

CHEMEON SURFACE TECHNOLOGY, LLC,
26 DEAN S. MEILING; and MADYLON
MEILING,
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Counter Defendants.
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Case No.: 3:15-cv-00294-MMD-CBC
STIPULATION AND ORDER FOR
EXTENSION OF TIME TO FILE
RESPONSE TO GREG SEMAS’S
RENEWED MOTION FOR SUMMARY
JUDGMENT [DKT 427]
[SECOND REQUEST]

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Plaintiff CHEMEON Surface Technology (“CHEMEON”), by and through its undersigned

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counsel, Timothy A. Lukas of Holland & Hart, LLP; and Defendant Greg Semas (“Semas”), by and

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through his undersigned counsel, Michael D. Hoy of Hoy Chrissinger Kimmel Vallas, PC, stipulate

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and agree as follows:

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1.

On July 25, 2018, Semas filed a Renewed Motion for Summary Judgment (Dkt. 427)

(“Motion”).

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2.

Chemeon’s deadline to file a response to the Motion was August 15, 2018.

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3.

Chemeon and Semas stipulated to extend the deadline for Chemeon to respond to the

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5441 Kietzke Lane, 2nd Floor
Reno, NV 89511
Phone: [phone] ♦ Fax: [phone]

HOLLAND & HART LLP

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Motion to September 7, 2018. The Court approved the Stipulation. (ECF 432).
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Chemeon and Semas hereby stipulate to further extend the deadline for Chemeon to

respond to the Motion to September 10, 2018.
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This is Chemeon’s second request for an extension of time to file a response to the

Motion.
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Pursuant to LR IA 6-1, this second request for an extension is made with good cause

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and in good faith and not for purposes of delay. Due to personnel departures of prior associated

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counsel and the availability of the remaining counsel for Chemeon, it be would very difficult and

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impose an undue burden on their client and counsel to meet the current filing deadline for filing an

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opposition to Greg Semas’ renewed motion for summary judgment in this case. Counsel do not

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believe that the short extension requested would cause any undue delay in this case. Chemeon’s

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counsel believes the extension allows for a better and more complete resolution of the pending

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motion and claims that may ultimately have to tried to the Court.

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IT IS SO STIPULATED.

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DATED this 7th day of September, 2018.

DATED this 7th day of September, 2018.

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HOLLAND & HART LLP

HOY CHRISSINGER KIMMEL PC

/s/ Timothy A. Lukas
Robert C. Ryan (7164)
Timothy A. Lukas (#4678)
5441 Kietzke Lane, Second Floor
Reno, Nevada 89511
Attorneys for Chemeon Surface Technology

/s/ Michael D. Hoy
Michael D. Hoy (2723)
Bank of America Tower
50 West Liberty Street, Suite 840
Reno, Nevada 89501
Attorneys for Greg D. Semas

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IT IS SO ORDERED.

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UNITED STATES DISTRICT JUDGE

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DATED: September 10, 2018

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5441 Kietzke Lane, 2nd Floor
Reno, NV 89511
Phone: [phone] ♦ Fax: [phone]

HOLLAND & HART LLP

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Case 3:15-cv-00294-MMD-CBC Document 434 Filed 09/07/18 Page 4 of 4

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PROOF OF SERVICE

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5441 Kietzke Lane, 2nd Floor
Reno, NV 89511
Phone: [phone] ♦ Fax: [phone]

HOLLAND & HART LLP

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Pursuant to FRCP 5, I declare, as follows:
I am employed in the City of Reno, County of Washoe, State of Nevada, by the law offices
of Holland & Hart. My business address is 5441 Kietzke Lane, Second Floor, Reno, Nevada 89511.
I am over the age of 18 years and not a party to this action.
I am readily familiar with Holland & Hart’s practice for collection and processing of: HAND
DELIVERIES, FACSIMILES and OUTGOING MAIL. Such practice in the ordinary course of
business provides for the delivery or faxing and/or mailing with the United States Postal Service, to
occur on the same day the document is collected and processed.
On September 7, 2018, I served the foregoing, STIPULATION AND ORDER FOR
EXTENSION OF TIME TO FILE RESPONSE TO GREG SEMAS’S RENEWED MOTION
FOR SUMMARY JUDGMENT [DKT 427] [SECOND REQUEST], as follows:



ELECTRONIC: by electronic transmission through the United States District Court’s
CM/ECF system to the parties below:

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Michael D. Hoy
HOY CHRISSINGER KIMMEL
Bank of America Tower
50 West Liberty Street, Suite 840
Reno, Nevada 89501
Telephone: [phone]
Facsimile: [phone]
[e-mail]

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Attorneys for Defendants

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I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct, and that this declaration was executed on September 7, 2018.

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/s/ Jeanette Sparks

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11390960_1

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