Opinion
2:22-cv001169-RFB-DJA
08-11-2022
APEX OPERATIONS, LLC, a Nevada limited liability company; 420702 CONSULTING, LLC, a Nevada limited liability company; ZOHA DEVELOPMENT, LLC, a Nevada limited liability company; MACMAS REAL ESTATE AND AGRICULTURAL PRIVATE EQUITY OPPORTUNITY FUND, LLC a foreign country limited liability company; MICHAEL SASSANO, an individual; RONALD SASSANO, an individual, Plaintiffs, v. PAVEL ROSENBERG, and individual; MCIG, INC., a Wyoming corporation; BOTS, INC. a Puerto Rico corporation; OBITX, INC., a foreign corporation; DOE individuals I through X, inclusive; and ROE entities I through X, inclusive, Defendants.
JASON M. WILEY, ESQ. E. DANIEL KIDD, ESQ. WILEY PETERSEN ATTORNEYS FOR PLAINTIFFS
JASON M. WILEY, ESQ.
E. DANIEL KIDD, ESQ.
WILEY PETERSEN
ATTORNEYS FOR PLAINTIFFS
STIPULATION AND ORDER TO EXTEND TIME TO FILE PLAINTIFFS' RESPONSE TO DEFENDANT EVERYTHING BLOCKCHAIN, INC.'S MOTION TO DISMISS UNDER FRCP 12(B)(2) AND, ALTERNATIVELY, FRCP 12(B)(6) [FIRST REQUEST]
RICHARD F. BOULWARE UNITED STATES DISTRICT COURT
Plaintiffs Apex Operations, LLC, 420702 Consulting, LLC, Zoha Development, LLC, MacMas Real Estate and Agricultural Private Equity Opportunity Fund, Michael Sassano, and Ronald Sassano, (collectively, “Plaintiffs”) by and through their attorneys of record, the law firm Wiley Petersen, and Defendant Everything Blockchain, Inc. (“EBI”) by and through its attorney of record, the law firm McDonald Carano (collectively, Plaintiffs and EBI referred to hereinafter as “the Parties”), and pursuant to LR IA 6-1, submit the following stipulation to extend the time for Plaintiffs to file a response to Defendant Everything Blockchain, Inc.'s Motion to Dismiss Under FRCP 12(b)(2) and, Alternatively, FRCP 12(b)(6) (“Motion to Dismiss”) [ECF No. 5]. In support of the stipulation, the Parties state that:
1. On July 20, 2022, EBI removed the litigation to this Court [ECF No. 1].
2. On July 27, 2022, EBI filed its Motion to Dismiss.
3. Plaintiffs require additional time to analyze the merits of the Motion to Dismiss and file a response.
4. EBI's counsel has acknowledged and agreed to the requested extension.
5. This is the first request to extend Plaintiffs' deadline to file a responsive pleading to the Motion to Dismiss.
6. The request for an extension of time to file a responsive pleading is not intended to cause any undue delay or prejudice to any party and is not made for an improper purpose.
7. The Parties stipulate that the deadline for Plaintiffs to file their responsive pleading to the Motion to Dismiss shall be extended through August 24, 2022.
ORDER