Incentive Capital v. Camelot Entertainment Group et al

Filing 86

STIPULATION re 47 MOTION to Quash service pursuant to Rule 12(b)(5) by Incentive Capital. (Pia, Joseph)

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Joseph G. Pia (9945) Nathan S. Dorius (8977) PIA ANDERSON DORIUS REYNARD & MOSS 222 South Main Street, Suite 1800 Salt Lake City, Utah 84101 Telephone: (801) 350-9000 Facsimile: (801) 950-9010 E-mail: Attorneys for Plaintiffs IN THE UNITED STATES DISTRICT COURT DISTRICT OF UTAH, CENTRAL DIVISION INCENTIVE CAPITAL, LLC, a Utah Limited Liability Company, STIPULATION TO PETER JAROWEY JR.’S MOTION TO QUASH SERVICE [DOCKET ENTRY NO. 47] Plaintiff, v. Civil No. 2:11-cv-00288-CW CAMELOT ENTERTAINMENT GROUP, INC., a Delaware Corporation; CAMELOT FILM GROUP, INC., a Nevada Corporation; CAMELOT DISTRIBUTION GROUP, INC., a Nevada Corporation, ROBERT P. ATWELL, an individual; JAMIE R. THOMPSON, an individual; STEVEN ISTOCK, an individual; TED BAER, an individual; PETER JAROWEY, an individual, Judge Clark Waddoups Defendants. Plaintiff Incentive Capital, LLC (“Plaintiff” or “Incentive”), by and through its counsel, respectfully files this Stipulation to Defendant Peter Jarowey Jr.’s Motion to Quash Service as follows: 1   Since the time Defendant Jarowey Jr. filed his Motion to Quash Service, counsel for Incentive has engaged in multiple communications with Mr. Jarowey’s counsel, and on information and belief, understands that it accidentally served the son of Peter Jarowey Sr. who committed the acts alleged in the Complaint. To cure this defect, on July 21, 2011, Plaintiff reissued sommons for service on Peter Jarowey Sr. [Docket Entry No. 72]. Service on Mr. Jarowey Sr. was effectuated on July 23, 2011 and returned executed to the Court on July 29, 2011 [Docket Entry No. 78]. According to the docket, Mr. Jarowey Sr. is required to file a responsive pleading by August 22, 2011. Consquently, Incentive stipulates to the Motion to Quash Service of Peter Jarowey Jr. DATED this 5th day of August, 2011. PIA ANDERSON DORIUS REYNARD & MOSS /s/ Joseph Pia Joseph Pia Attorneys for Plaintiff 2   CERTIFICATE OF SERVICE I hereby certify that on this 5th day of August, 2011, a true and correct copy of forgoing STIPULATION TO PETER JAROWEY JR.’S MOTION TO QUASH SERVICE [DOCKET ENTRY NO. 47] was served by electronic mail on the following: John A. Snow Karen E. O’Brien VAN COTT BAGLEY CORNALL & McCARTHY Jonathan M. Levitan Wayne G. Petty MOYLE & DRAPER, P.C. Marc E. Kasowitz David J. Shapiro KASOWITZ, BENSON, TORRES & FRIEDMAN LLP By: /s/ Joseph Pia 3  

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