WNDG, LLC v. Lantow, as Trustee of The Susan Lantow Living Trust Dated May 26, 2006 ( 2024 )

Nevada Bar No.: 1798 2 Johnathon Fayeghi, Esq. Nevada Bar No.: 12736 3 SKLAR WILLIAMS PLLC 410 South Rampart Boulevard, Suite 350 4 Las Vegas, NV 89145 5 Telephone: (702) 360-6000 Facsimile: (702) 360-0000 6 Email: fberkley@sklar-law.com jfayeghi@sklar-law.com 7 Attorneys for Defendant 8 UNITED STATES DISTRICT COURT 9 DISTRICT OF NEVADA 10 WNDG, LLC, an Arizona limited liability CASE NO.: 2:24-cv-00263-CDS-BNW company, 11 12 Plaintiff, STIPULATION AND ORDER TO EXTEND DEADLINE FOR DEFENDANT 13 vs. TO ANSWER OR RESPOND TO PLAINTIFF’S COMPLAINT 14 Susan Lantow as Trustee of The Susan Lantow (FIRST REQUEST) Living Trust Dated May 26, 2006. 15 Defendant. 16 17 IT IS HEREBY STIPULATED AND AGREED, by and between Plaintiff WNDG, LLC 18 (“Plaintiff”), through its undersigned counsel of record and Defendant Susan Lantow as Trustee 19 of The Susan Lantow Living Trust Dated May 26, 2006 (“Defendant”), through her undersigned 20 counsel of record, as follows: 21 1. On February 6, 2024, Plaintiff filed its Complaint alleging claims for relief for 22 breach of contract and negligent misrepresentation against Defendant. ECF 1. 23 2. On or about March 17, 2024, Plaintiff allegedly served the Summons and 24 Complaint on Defendant. ECF 10. 25 3. Defendant was unable to retain counsel to respond to the Complaint until April 2, 26 2024. 27 28 1 4. Accordingly, pursuant to LR IA 6-1(a), the Parties wish to extend the deadline for 2 || Defendant to respond to the Complaint by approximately 4 days in order to allow Defendant’s 3 || counsel to adequately investigate the facts and prepare a responsive pleading. 4 5. For these reasons, the Parties stipulate and agree that Defendant shall have up to 5 || and including April 12, 2024, within which to file her response to Plaintiff’s Complaint. 6 6. No discovery deadlines or dates for trial have been set. 7 7. This is the Parties’ first request to extend Defendant’s response deadline. 8 8. This stipulation is brought in good faith by the Parties and not for purposes of 7 delay. 10 IT IS SO STIPULATED. 1] DATED this 8th day of April, 2024. DATED this 8th day of April, 12 HOLLEY DRIGGS 2024. SKLAR WILLIAMS PLLC 13 /s/ Don C. Fletcher /s/ Johnathon Faveghi □□□ McKay Holley, Esq. Frederic I. Berkley, Esq. 15 Nevada Bar No. 15934 Nevada Bar No. 1798 300 South Fourth Street, Suite 1600 Johnathon Fayeghi, Esq. 16 || Las Vegas, NV 89101 Nevada Bar No. 12736 mholley@nevadafirm.com 410 S. Rampart Blvd., Ste. 350 17 -and- Las Vegas, NV 89145 FLETCHER BARNES LAW, PLC fberkley@sklar-law.com 18 || Don C. Fletcher, Esq. jfayeghi@sklar-law.com Arizona Bar No. 012140 Attorneys for Defendant 19 | 10429 South 51% Street, Suite 225 0 Phoenix, Arizona 85044 Attorneys for Plaintiff 21 IT IS SO ORDERED. 22 Ling olen nh boom 23 ITED STATES MAGISTRATE JUDGE 24 || DATED: _ 4/9/2024 25 26 27 28 From: John Fayeghi Sent: Monday, April 8, 2024 2:38 PM To: Amanda Brandon Cc: Frederic Berkley From: Don Fletcher Sent: Monday, April 8, 2024 2:04 PM To: John Fayeghi Cc: McKay Holley Subject: FW: WNDG, LLC v. Susan Lantow as Trustee of The Susan Lantow Living Trust Dated May 26, 2006 (Case 2:24-cv- 00263) External Email John: Yes, you have our permission to sign and file with the Court. Thank you. Don C. Fletcher FLETCHER BARNES LAW PLC 10429 South 51st Street, Suite 225 Phoenix, AZ 85044 602-523-3007 (Office) 602-471-8185 (cell) dfletcher@fletcherbarneslaw.com www.fletcherbarneslaw.com CONFIDENTIALITY NOTICE This electronic transmission and any attachments are the confidential property of the sender, and the materials are privileged communications intended solely for the receipt, use, benefit, and information of the intended recipient indicated above. If you are not the intended recipient, you are hereby notified that any review, disclosure, copying, distribution, or the taking of any other action in reliance on the contents of this electronic transmission is strictly prohibited, and may result in legal liability on your part. If you have received this transmission in error, please notify Fletcher Barnes Law PLC immediately by telephone at (602) 523-3007 or by email at dfletcher@fletcherbarneslaw.com and destroy this electronic transmission. From: John Fayeghi Sent: Monday, April 8, 2024 9:52 AM To: Don Fletcher ; mholley@nevadafirm.com Cc: Frederic Berkley ; Amanda Brandon ; Timothy Barnes Subject: RE: WNDG, LLC v. Susan Lantow as Trustee of The Susan Lantow Living Trust Dated May 26, 2006 (Case 2:24-cv- 00263)