Ach Foam Technologies, Inc v. Icon Reno Property Owner Pool 3 Nevada, LLC
Filing
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ORDER granting ECF No. 54 Stipulation for Extension of Time to Respond to ECF No. 52 Motion to Dismiss Counterclaim. Response due by 3/26/2019. Signed by Judge Miranda M. Du on 3/11/2019. (Copies have been distributed pursuant to the NEF - KW)
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G. DAVID ROBERTSON, ESQ. (NV Bar 1001)
KIRK C. JOHNSON, ESQ. (NV Bar 4299)
Robertson, Johnson, Miller & Williamson
50 West Liberty Street, Suite 600
Reno, Nevada 89501
Telephone No.: (775) 329-5600
Facsimile No.: (775) 348-8300
gdavid@nvlawyers.com
kirk@nvlawyers.com
Attorneys for Defendant/Counterclaimant ICON RENO
PROPERTY OWNER POOL 3 NEVADA, LLC
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UNITED STATES DISTRICT COURT
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DISTRICT OF NEVADA
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MFR HOLDCO, LLC, a foreign limited
liability company,
Case No. 3:18-cv-00034-MMD-WGC
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Plaintiff,
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vs.
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ICON RENO PROPERTY OWNER POOL 3
NEVADA, LLC, a foreign limited liability
Company,
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Defendants.
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ICON RENO PROPERTY OWNER POOL 3
NEVADA, LLC, a foreign limited liability
Company,
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Counterclaimant.
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vs.
MFR HOLDCO, LLC,; ACH FOAM
TECHNOLOGIES, INC.; FRANK
KIESECKER, JR., individually; RICHARD L.
WALLER, individually; MICHAEL S.
HUEMPFNER, individually,
Counterdefendants.
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Robertson, Johnson,
Miller & Williamson
50 West Liberty Street,
Suite 600
Reno, Nevada 89501
STIPULATION FOR EXTENSION OF TIME TO RESPOND TO
MOTION TO DISMISS COUNTERCLAIM
(FIRST REQUEST)
WHEREAS, Counterdefendants Kiesecker, Waller and Huempfner filed a Motion to
Dismiss Counterclaim (ECF 52) on February 26, 2019 (“the Motion”);
STIPULATION FOR EXTENSION OF TIME TO RESPOND TO MOTION TO DISMISS COUNTERCLAIM
(FIRST REQUEST)
PAGE 1
WHEREAS, Counterclaimant’s opposition to the Motion is currently due on or before
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March 12, 2019;
WHEREAS, the parties participated in a mediation on March 4, 2019, and reached a
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tentative settlement of the action;
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WHEREAS, the parties are working to finalize that tentative settlement;
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WHEREAS, the settlement will obviate the need for Counterclaimant to file an
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opposition to the Motion; and
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WHEREAS, the parties agree that the Counterclaimant should not be required to expend
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time and money opposing the Motion if the parties can finalize their settlement, such that an
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extension of time for Counterclaimaint to file said opposition, while the parties work to finalize
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their settlement, makes good sense,
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IT IS HEREBY STIPULATED AND AGREED by and between the undersigned, that
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Counterclaimant Icon Reno Property Owner Pool 3 Nevada, LLC shall have to and including
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March 26, 2019, to file its opposition to Plaintiff’s Motion to Dismiss Counterclaim in this
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action.
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IT IS SO STIPULATED:
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DATED: March 11, 2019
DATED: March 11, 2019.
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HOLLAND & HART LLP
ROBERTSON, JOHNSON
MILLER & WILLIAMSON
By: /s/ Matthew B. Hippler
Matthew B. Hippler, Esq.
Frank Z. LaForge, Esq.
Attorneys for Plaintiff/
Counterdefendants
By: /s/ Kirk C. Johnson
Kirk C. Johnson, Esq.
Attorneys for Defendant/
Counterclaimant
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ORDER
IT IS SO ORDERED:
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UNITED STATES DISTRICT JUDGE
March 11, 2019
DATED: ________________________
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Robertson, Johnson,
Miller & Williamson
50 West Liberty Street,
Suite 600
Reno, Nevada 89501
STIPULATION FOR EXTENSION OF TIME TO RESPOND TO MOTION TO DISMISS COUNTERCLAIM
(FIRST REQUEST)
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CERTIFICATE OF SERVICE
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Pursuant to FRCP 5(b) and Local Rule 5-4, I hereby certify that I am an employee of
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Robertson, Johnson, Miller & Williamson, over the age of eighteen, and not a party to the within
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action.
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STIPULATION FOR EXTENSION OF TIME TO RESPOND TO MOTION TO DISMISS
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COUNTERCLAIM (FIRST REQUEST) and thus, pursuant to LR 5-4, caused same to be
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served by electronic mail on the following Filing Users:
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I further certify that on the 11th day of March, 2019, I electronically filed this
Matthew B. Hippler, Esq. (SBN 7015)
Frank Z. LaForge, Esq. (SBN 12246)
Holland & Hart LLP
5441 Kietzke Lane, Second Floor
Reno, NV 89511
mhippler@hollandhart.com
lzlaforge@hollandhart.com
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/s/ Teresa W. Stovak
An Employee of Robertson, Johnson,
Miller & Williamson
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Robertson, Johnson,
Miller & Williamson
50 West Liberty Street,
Suite 600
Reno, Nevada 89501
STIPULATION FOR EXTENSION OF TIME TO RESPOND TO MOTION TO DISMISS COUNTERCLAIM
(FIRST REQUEST)
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