Opinion
2:22-cv-01965-JAD-EJY
12-22-2022
PETER SCHULTZ, individually and as trustee of the SUNSHINE AND RAIN ASSET MANAGEMENT IRREVOCABLE TRUST, Plaintiff, v. AMERICAN BATTERY TECHNOLOGY COMPANY, INC. a Nevada Corporation; ACTION STOCK TRANSFR COMPANY, INC., a Utah Corporation, and DOES 1 to 10, inclusive, Defendants.
GORDON REES SCULLY MANSUKHANI, LLP CHRISTOPHER B. QUEALL, BRADLEY G. TAYLOR, ESQ. ATTORNEYS FOR PLAINTIFF PETER SCHULTZ, INDIVIDUALLY AND AS TRUSTEE OF THE SUNSHINE AND RAIN ASSET MANAGEMENT IRREVOCABLE TRUST. DICKINSON WRIGHT PLLC MICHAEL N. FEDER GABRIEL A. BLUMBERG ATTORNEYS FOR DEFENDANT AMERICAN BATTERY TECHNOLOGY, COMPANY, INC.
GORDON REES SCULLY MANSUKHANI, LLP CHRISTOPHER B. QUEALL, BRADLEY G. TAYLOR, ESQ. ATTORNEYS FOR PLAINTIFF PETER SCHULTZ, INDIVIDUALLY AND AS TRUSTEE OF THE SUNSHINE AND RAIN ASSET MANAGEMENT IRREVOCABLE TRUST.
DICKINSON WRIGHT PLLC MICHAEL N. FEDER GABRIEL A. BLUMBERG ATTORNEYS FOR DEFENDANT AMERICAN BATTERY TECHNOLOGY, COMPANY, INC.
STIPULATION AND [PROPOSED] ORDER EXTENDING TIME FOR DEFENDANT AMERICAN BATTERY TECHNOLOGY COMPANY, INC. TO RESPOND TO PLAINTIFF PETER SCHULTZ'S COMPLAINT
[FIRST REQUEST]
Defendant American Battery Technology Company, Inc. (“ABTC”), by and through its attorneys, Dickinson Wright PLLC, and Plaintiff Peter Schultz, individually and as Trustee of the Sunshine and Rain Asset Management Irrevocable Trust (collectively “Schultz”), by and through his attorneys, Gordon Rees Scully Mansukhani, LLP, stipulate and agree as follows:
1. Schultz filed his Complaint [ECF 1] (the “Complaint”) on November 22, 2022.
2. Schultz served ABTC on or about December 7, 2022.
3. ABTC's deadline to respond, move or otherwise plead to the Complaint is December 28, 2022.
4. Schultz and ABTC have agreed that ABTC shall have up to and including January 11, 2023, to respond, move or otherwise plead to the Complaint.
5. The request for an extension is because the current deadline falls in the middle of the holidays and ABTC needs additional time to review its records pertaining to the allegations in the Complaint.
6. This is the first stipulation between ABTC and Schultz to extend the time for ABTC to respond, move or otherwise plead to the Complaint and it is not being entered into for purposes of any delay.
ORDER
IT IS SO ORDERED.