Opinion
2:22-CV-01415
10-04-2022
NBK INNOVATIONS XIII, LLC, DOJO VENTURES FUND II, LLC, SU FUND I, A SERIES OF INCISIVE VENTURES LP, ANTONIO SALERNO, SUSAN LEIBY, ALESSCO, INC. DEFINED BENEFIT PLAN, ROBERT HESS, AND MJ JAMIOLKOWSKI FLP, Plaintiffs, v. SUAVEI, INC., AFONSO INFANTE, AND ALLISON WONG, Defendant.
HOWARD & HOWARD ATTORNEYS PLLC L. Christopher Rose, Esq. Nevada Bar No. 7500 Jonathan R. Martin, Esq. Nevada Bar No. 15959 Attorneys for Defendant Allison Wong HUTCHISON & STEFFEN, PLLC Stewart C. Fitts, Esq. Nevada Bar No. 5635 Peccole Professional Park Attorneys for Plaintiffs NBK Innovations XIII, LLC, Dojo Ventrues Fund II, LLC, Su Fund I, A Series of Incisive Ventures LP, Antonio Salerno, Susan Leiby, Alessco, Inc. Defined Benefit Plan, Robert Hess, and MJ Jamiolkowski FLP
HOWARD & HOWARD ATTORNEYS PLLC L. Christopher Rose, Esq. Nevada Bar No. 7500 Jonathan R. Martin, Esq. Nevada Bar No. 15959 Attorneys for Defendant Allison Wong
HUTCHISON & STEFFEN, PLLC Stewart C. Fitts, Esq. Nevada Bar No. 5635 Peccole Professional Park Attorneys for Plaintiffs NBK Innovations XIII, LLC, Dojo Ventrues Fund II, LLC, Su Fund I, A Series of Incisive Ventures LP, Antonio Salerno, Susan Leiby, Alessco, Inc. Defined Benefit Plan, Robert Hess, and MJ Jamiolkowski FLP
STIPULATION AND ORDER TO EXTEND TIME FOR DEFENDANT ALLISON WONG TO ANSWER OR OTHERWISE RESPOND TO COMPLAINT
(FIRST REQUEST)
Pursuant to Rule 6(b) of the Federal Rules of Civil Procedure and District of Nevada Local Rule IA 6-1, Plaintiffs NBK Innovations XIII, LLC, DOJO Ventures Fund II, LLC, Su Fund I, A Series of Incisive Ventures LP, Antonio Salerno, Susan Leiby, Alessco, Inc. Defined Benefit Plan, Robert Hess, and MJ Jamiolkowski FLP, (“Plaintiffs”) and Defendant Allison Wong (“Defendant” or “Wong”), through counsel, hereby agree and stipulate, as follows:
1. Plaintiffs filed their Complaint (the “Complaint”) on August 30, 2022.
2. Plaintiffs served the Summons and Complaint on Defendant on September 6, 2022.
3. Pursuant to Rule 12(a)(1)(A)(i) of the Federal Rules of Civil Procedure, Defendant had 21 days from the date of service to file and serve an answer or other response to the Complaint (i.e., until September 27, 2022).
4. Defendant and Plaintiffs stipulate to a 30-day extension of time to file and serve an answer or other respond to the Complaint, which makes the response due on October 27, 2022.
5. The reason for the extension is that Defendant's counsel has been investigating the circumstances surrounding the allegations since being retained and has also engaged in a telephonic conference with Plaintiffs' counsel in an effort to discuss and, if possible, resolve the dispute. The parties have agreed to have further discussions as well.
6. The parties timely filed a stipulation within the time required for the original response. Upon receipt of the order denying the stipulation, the parties prepared this revised stipulation and have submitted it as soon as time allowed. Thus, to the extent required, the failure to file a response to the complaint was the result of excusable neglect as the parties attempted to submit a timely stipulation to extend the deadline.
7. This is the first stipulation to extend the date for Defendant to answer or otherwise respond to the Complaint.
IT IS SO AGREED AND STIPULATED:
IT IS SO ORDERED:
(Exhibit Omitted).