Promedev LLC v. Age Relief LLC et al

Filing 9

ORDER. Defendants may have until 2/17/2023 to file and serve a response to the Complaint. Signed by Judge Ricardo S. Martinez. (SB)

Case 2:22-cv-01824-RSM Document 9 Filed 01/18/23 Page 1 of 4

1

THE HONORABLE RICARDO S. MARTINEZ

2
3
4
5
6
7

UNITED STATES DISTRICT COURT
WESTERN DISTRICT OF WASHINGTON
AT SEATTLE

8
9

PROMEDEV, LLC dba RELIEF FACTOR,

10

Plaintiff,

11
12
13
14

v.
AGE RELIEF, LLC; and MICHAEL JOSEPH
REDMOND,

CASE NO. 2:22-cv-01824-RSM
STIPULATION AND ORDER TO
EXTEND TIME TO RESPOND TO
COMPLAINT
NOTE ON MOTION CALENDAR:
Tuesday, January 17, 2023

Defendants.

15

Plaintiff Promedev, LLC dba Relief Factor (“Plaintiff”) and defendants Age Relief, LLC

16

and Michael Joseph Redmond (“Defendants”) (collectively, the “Parties”), by and through their

17

respective counsel, hereby stipulate and agree as follows:

18

WHEREAS, Plaintiff filed its Complaint on December 28, 2022;

19

WHEREAS, Defendants were served with the Complaint on December 30, 2022, making

20
21
22

their current response deadline January 20, 2023;
WHEREAS, Defendants’ counsel were recently retained and are currently evaluating the
underlying facts, Plaintiff’s allegations, as well as potential defenses;

23

WHEREAS, Defendants have not previously sought any extension of time;

24

WHEREAS, the Parties agree to extend the deadline by which Defendants may respond to

25
26
27

the Complaint to February 17, 2023;
WHEREFORE, IT IS HEREBY STIPULATED AND AGREED TO BY THE PARTIES,
that Defendants may have until February 17, 2023 to file and serve a response to the Complaint.
STIPULATION AND ORDER TO EXTEND
DEADLINE TO RESPOND TO COMPLAINT - 1
CASE NO. 2:22-cv-01824-RSM

GOLDFARB & HUCK
ROTH RIOJAS, PLLC

925 Fourth Avenue, Suite 3950
Seattle, Washington 98104
[phone]

Case 2:22-cv-01824-RSM Document 9 Filed 01/18/23 Page 2 of 4

1

RESPECTFULLY SUBMITTED on this 17th day of January, 2023.

2

GOLDFARB & HUCK ROTH RIOJAS, PLLC

3

/s/Kit W. Roth
Kit W. Roth, WSBA No. 33059
/s/R. Omar Riojas
R. Omar Riojas, WSBA No. 35400

4
5

8

925 Fourth Avenue, Suite 3950
Seattle, WA 98104
Telephone: [phone]
Facsimile: 206.397.3062
E-mail: [e-mail]
[e-mail]

9

Attorneys for Defendants

6
7

10

LOWE GRAHAM JONES PLLC

11

s/ David A. Lowe
David A. Lowe, WSBA No. 24453

12
13
14
15
16

1325 Fourth Ave., Suite 1130
Seattle, WA 98101
Telephone: [phone]
Email: [e-mail]
Attorneys for Plaintiff

17
18
19
20
21
22
23
24
25
26
27
STIPULATION AND ORDER TO EXTEND
DEADLINE TO RESPOND TO COMPLAINT - 2
CASE NO. 2:22-cv-01824-RSM

GOLDFARB & HUCK
ROTH RIOJAS, PLLC

925 Fourth Avenue, Suite 3950
Seattle, Washington 98104
[phone]

Case 2:22-cv-01824-RSM Document 9 Filed 01/18/23 Page 3 of 4

1

ORDER

2

Pursuant to the above stipulation, IT IS SO ORDERED.

3

DATED this 18th day of January, 2023

4
5

A

6

RICARDO S. MARTINEZ
UNITED STATES DISTRICT JUDGE

7
8
9
10
11
12
13
14
15
16
17
18

Presented by:
/s/Kit W. Roth
Kit W. Roth, WSBA No. 33059
/s/R. Omar Riojas
R. Omar Riojas, WSBA No. 35400
GOLDFARB & HUCK ROTH RIOJAS, PLLC
925 Fourth Avenue, Suite 3950
Seattle, WA 98104
Telephone: [phone]
Facsimile: 206.397.3062
E-mail: [e-mail]
Attorney for Defendants

19
20
21
22
23
24
25
26
27
STIPULATION AND ORDER TO EXTEND
DEADLINE TO RESPOND TO COMPLAINT - 3
CASE NO. 2:22-cv-01824-RSM

GOLDFARB & HUCK
ROTH RIOJAS, PLLC

925 Fourth Avenue, Suite 3950
Seattle, Washington 98104
[phone]

Case 2:22-cv-01824-RSM Document 9 Filed 01/18/23 Page 4 of 4

1

CERTIFICATE OF SERVICE

2

The undersigned certifies that the foregoing document was filed electronically with the

3

Clerk of the Court using the CM/ECF system on January 17, 2023 and was served via the Court’s

4

CM/ECF system on all counsel of record.

5
6

/s/ Kit W. Roth
Kit W. Roth, WSBA No. 33059

7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
STIPULATION AND ORDER TO EXTEND
DEADLINE TO RESPOND TO COMPLAINT - 4
CASE NO. 2:22-cv-01824-RSM

GOLDFARB & HUCK
ROTH RIOJAS, PLLC

925 Fourth Avenue, Suite 3950
Seattle, Washington 98104
[phone]