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)

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: [phone]
Facsimile: [phone]
E-mail: [e-mail]
[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:
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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
[e-mail]
[e-mail]
Jonathan M. Levitan
[e-mail]
Wayne G. Petty
MOYLE & DRAPER, P.C.
[e-mail]
Marc E. Kasowitz
David J. Shapiro
KASOWITZ, BENSON, TORRES & FRIEDMAN LLP
[e-mail]
[e-mail]

By: /s/ Joseph Pia

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