Menos v. Taylor et al

Filing 46

ORDER granting ECF No. 45 Stipulation to Extend Deadline for Plaintiff's Response to ECF No. 42 Motion to Dismiss and Defendants' Reply Thereto (First Request). Response due by 11/26/2018. Reply due by 12/17/2018. Signed by Judge Larry R. Hicks on 10/3/2018. (Copies have been distributed pursuant to the NEF - LH)

Case 3:17-cv-00662-LRH-CBC Document 45 Filed 10/01/18 Page 1 of 3

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Patrick R. Leverty, Esq.
LEVERTY & ASSOCIATES LAW CHTD.
Reno Gould House
832 Willow Street
Reno, NV 89502
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Phillip Kim
THE ROSEN LAW FIRM, P.A.
275 Madison Avenue, 34th Floor
New York, NY 10016
Telephone: [phone]
Facsimile: [phone]
Email: [e-mail]
Counsel for Plaintiff

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UNITED STATES DISTRICT COURT

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DISTRICT OF NEVADA

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HANS MENOS, derivatively on behalf of
ECO SCIENCE SOLUTIONS, INC.,

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Plaintiff,
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINE FOR
PLAINTIFF’S RESPONSE TO MOTION
TO DISMISS AND DEFENDANTS’
REPLY THERETO

v.
JEFFERY L. TAYLOR, DON L.
TAYLOR, L. JOHN LEWIS, S.
RANDALL OVESON, and GANNON
GIGUIERE,

(First Request)

Defendants,

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Case No. 3:17-CV-00662-LRH-CBC

and

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ECO SCIENCE SOLUTIONS, INC.,

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Nominal Defendant.

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Case 3:17-cv-00662-LRH-CBC Document 45 Filed 10/01/18 Page 2 of 3

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Pursuant to LR IA 6-1, LR IA 6-2, and LR 7-1, Plaintiff Hans Menos, by and through his

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counsel the law firms of Leverty & Associates Law Chtd. Ltd. and The Rosen Law Firm, P.A. and

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Defendants Jeffery L. Taylor, Don L. Taylor, L. John Lewis, S. Randall Oveson and Gannon

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Giguiere (collectively, “Individual Defendants”) and Nominal Defendant Eco Science Solutions,

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Inc. (“Nominal Defendant” and with Individual Defendants, “Defendants”), by and through their

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counsel, the law firm of Greenberg Traurig, LLP, hereby stipulate and agree to extend the deadline

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for Plaintiff to respond to Defendants’ Motion to Dismiss Verified Stockholder Derivative

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Complaint, filed on September 27, 2018 as Dkt. No. 42 (the “Motion to Dismiss”), by forty-five

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(45) days, through and including November 26, 2018, and request that the Court enter an order

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approving the same. Currently, Plaintiff’s opposition to the Motion to Dismiss is due on October

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11, 2018.

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Counsel for Plaintiff requests additional time due to several upcoming deadlines which

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would make it difficult to file an opposition timely. Defendants’ counsel have agreed to the

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extension as a professional courtesy.

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Counsel for Plaintiff and counsel for Defendants hereby further stipulate and agree that

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Defendants’ reply to Plaintiff’s response shall be due twenty-one (21) days thereafter, through and

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including December 17, 2018, and request that the Court enter an order approving the same.

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This is the first stipulation for an extension of time for Plaintiff to respond to the Motion
to Dismiss and for Defendants’ reply thereto.
Dated: October 1, 2018

By: /s/Patrick R. Leverty______________
Patrick R. Leverty
LEVERTY & ASSOCIATES LAW CHTD.
832 Willow Street
Reno, NV 89502

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Phillip Kim
THE ROSEN LAW FIRM, P.A.
275 Madison Avenue, 34th Floor
New York, NY 10016

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Attorneys for Plaintiff
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Case 3:17-cv-00662-LRH-CBC Document 45 Filed 10/01/18 Page 3 of 3

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Dated: October 1, 2018

By: /s/Joel M. Eads___________________
_ Mark E. Ferrario
Christopher R. Miltenberger
GREENBERG TRAURIG, LLP
3773 Howard Hughes Parkway
Suite 400 North
Las Vegas, NV 89169

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Joel M. Eads
GREENBERG TRAURIG, LLP
2700 Two Commerce Square
2001 Market Street
Philadelphia, PA 19103

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Attorneys for
Defendant

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Defendants

and

Nominal

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IT IS SO ORDERED:
DATED this 3rd day of October, 2018.
________________________________________________
UNITED STATES DISTRICT/MAGISTRATE JUDGE
DATED: ____________________
________________________________
LARRY R. HICKS
UNITED STATES DISTRICT JUDGE

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