Barrow v. Helicopter Parts International, Inc. et al

Filing 39

ORDER granting ECF No. 38 Stipulation. Defendants shall file their Reply in Support of Defendants' Motion to Dismiss First Amended Complaint (ECF No. 24 ) on or before January 13, 2021. Signed by Chief Judge Miranda M. Du on 1/7/2021. (Copies have been distributed pursuant to the NEF - AB)

Case 3:20-cv-00528-MMD-CLB Document 39 Filed 01/07/21 Page 1 of 2

1 ANTHONY L. HALL, ESQ.
Nevada Bar No. 5977
2 [e-mail]
JONATHAN A. MCGUIRE, ESQ.
3 Nevada Bar No. 15280
[e-mail]
4 SIMONS HALL JOHNSTON PC
6490 S. McCarran Blvd., Ste. F-46
5 Reno, Nevada 89509
Telephone: [phone]
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Attorneys for Defendants Helicopter
7 Parts International, Inc., Harry
Niwranski, and Anthony Magnotta
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6490 S. McCarran Blvd., Ste. F-46
Reno, NV 89509
Phone: [phone]

SIMONS HALL JOHNSTON PC

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UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA

14 ERICA BARROW, an individual
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Plaintiff,

16 v.
17 HELICOPTER PARTS INTERNATIONAL,
INC., a Nevada Corporation; HARRY
18 NIWRANSKI, an individual; ANTHONY
MAGNOTTA; DOES I through X, Inclusive;
19 and ROE CORPORATIONS I through X,
inclusive,
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Defendants.
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CASE NO.: 3:20-cv-00528-MMD-CLB
STIPULATION AND [PROPOSED]
ORDER TO EXTEND DEADLINE FOR
DEFENDANT TO FILE A REPLY IN
SUPPORT OF DEFENDANTS’ MOTION
TO DISMISS FIRST AMENDED
COMPLAINT PURSUANT TO FRCP
12(b)(6)
(Second Request)

Plaintiff Erica Barrow (“Barrow”) and Defendants Helicopter Parts International, Inc.

23 (“HPI”), Harry Niwranski (“Niwranski”), and Anthony Magnotta (“Magnotta”) (collectively, when
24 possible, “Defendants”), by and through their respective counsel, hereby submit the following
25 Stipulation and [Proposed] Order to Extend Deadline for Defendant to file a Reply in Support of
26 Defendants’ Motion to Dismiss First Amended Complaint Pursuant to FRCP 12(b)(6). Defendants
27 seek a one-week extension to file their Reply. The parties previously stipulated to a two-week
28 extension to file this reply in light of defense counsel’s schedule and the holiday season. This
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Case 3:20-cv-00528-MMD-CLB Document 39 Filed 01/07/21 Page 2 of 2

1 request is made in good faith to accommodate the associate attorney on the case as he has fallen ill
2 and is unable to work, and is not made for the purpose of delay, and will not result in any undue
3 delay or prejudice. Accordingly, the Parties have agreed and stipulate that the deadline for the
4 Defendants to file their Reply in Support of Defendants’ Motion to Dismiss First Amended
2021.
5 Complaint Pursuant to FRCP 12(b)(6) will be on or before January 13, 2020.
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BY:

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6490 S. McCarran Blvd., Ste. F-46
Reno, NV 89509
Phone: [phone]

SIMONS HALL JOHNSTON PC

DATED this 6th day of January, 2021.

DATED this 6th day of January, 2021.

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/s/ Matthew C. Piccolo
PICCOLO LAW OFFICES
8565 S Eastern Ave Ste 150
Las Vegas, NV 89123
[phone]
[e-mail]

BY: /s/ Jonathan A. McGuire
ANTHONY L. HALL, ESQ.
Nevada Bar No. 5977
JONATHAN A. MCGUIRE, Esq.
Nevada Bar No. 15280
SIMONS HALL JOHNSTON PC
6490 S. McCarran Blvd., Ste. F-46
Reno, Nevada 89509
Telephone: [phone]

.

Attorneys for Plaintiff

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Attorneys for Defendants

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IT IS SO ORDERED:

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January 7
Dated: _____________________, 2021.
_____________________________________________
UNITED STATES DISTRICT JUDGE

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