Opinion
2:22-cv-02004-APG-NJK
12-28-2022
ANTHONY AMEEN, an Individual, Plaintiff, v. PROFESSIONAL RODEO COWBOYS ASSOCIATION, INC., a Colorado non-profit corporation, and RURAL MEDIA GROUP, INC., d/b/a THE COWBOY CHANNEL, a Delaware corporation, Defendants.
AMTOJ RANDHAWA BRYAN CAVE LEIGHTON PAISNER LLP ATTORNEYS FOR DEFENDANT, PROFESSIONAL RODEO COWBOYS ASSOCIATION DAVID G. BRAY DICKINSON WRIGHT PLLC GABRIEL A. BLUMBERG DICKINSON WRIGHT PLLC ATTORNEYS FOR PLAINTIFF, ANTHONY AMEEN
AMTOJ RANDHAWA BRYAN CAVE LEIGHTON PAISNER LLP ATTORNEYS FOR DEFENDANT, PROFESSIONAL RODEO COWBOYS ASSOCIATION
DAVID G. BRAY DICKINSON WRIGHT PLLC GABRIEL A. BLUMBERG DICKINSON WRIGHT PLLC ATTORNEYS FOR PLAINTIFF, ANTHONY AMEEN
ORDER EXTENDING TIME FOR DEFENDANT PROFESSIONAL RODEO COWBOYS ASSOCIATION TO RESPOND TO PLAINTIFF'S COMPLAINT
(First Request)
Hon. Nancy J. Koppe United States-Magistrate Judge
Plaintiff Anthony Ameen (hereinafter “Plaintiff”) and Defendant Professional Rodeo Cowboys Association (hereinafter “Defendant”) (collectively, the “Parties”), by and through their undersigned counsel, hereby stipulate and agree as follows:
WHEREAS, Plaintiff filed a Complaint in the District Court of Clark County Nevada in an action styled Anthony Ameen v. Professional Rodeo Cowboys Association, Inc. et al., Case No. A-22-858529-C, on September 16, 2022 (hereinafter the “State Court Action”);
WHEREAS, Plaintiff filed an Amended Complaint in the State Court Action on October 25, 2022;
WHEREAS, Plaintiff served Defendant with the Amended Complaint on November 1, 2022;
WHEREAS, the Parties agreed that Defendant's deadline to respond to the Amended Complaint would be extended from November 22, 2022 to January 6, 2023;
WHEREAS, Defendant Rural Media Group, Inc. (hereinafter “RMG”) removed the State Court Action to this Court on November 30, 2022;
WHEREAS, Defendant has been actively engaged in discussions regarding applicable indemnification agreements and the appointment of defense counsel by the indemnifying party or an insurer;
WHEREAS, the deadline for Defendant to file a special motion to dismiss under Nevada's anti-SLAPP statute is January 2, 2023. See NRS 41.660(2) (anti-SLAPP motion is due within 60 days of service of the complaint);
WHEREAS, each of these deadlines can be extended by the Court upon good cause. See Fed.R.Civ.P. 6(b)(1); NRS 41.660(2);
WHEREAS, Plaintiff has agreed to a further 14-day extension of time for Defendant to respond to the Amended Complaint, through and including January 20, 2023, to provide additional time for Defendant to investigate Plaintiff's allegations, prepare a response, and explore the possibility of resolving Plaintiff's claims;
WHEREAS, this is the first request for an extension to this Court, and it is made in good faith and not for purposes of delay;
NOW, THEREFORE, the parties hereby stipulate that Defendant's deadline to file a response to Plaintiff's Amended Complaint shall be extended to, and includes, January 20, 2023.
IT IS SO STIPULATED.
ORDER
Having read the Parties' foregoing Stipulation, IT IS HEREBY ORDERED that Defendant Professional Rodeo Cowboys Association's response to Plaintiff's Amended Complaint shall now be due on or before January 20, 2023.