Fowler v. Sequium Asset Solutions, LLC

1 ROBERT S. LARSEN, ESQ.

Nevada Bar No. 7785 GORDON REES SCULLY MANSUKHANI, LLP South 4th Street, Suite 1550 Las Vegas, Nevada 89101 Telephone: (702) 577-9300 Facsimile: (702) 255-2858 E-Mail: [email protected] Attorneys for Sequium Asset Solutions, LLC UNITED STATES DISTRICT COURT DISTRICT OF NEVADA DEBORAH FOWLER, an individual, Case No.: 2:19-CV-01979-APG-DJA Plaintiff, vs. STIPULATION AND ORDER TO 12 EXTEND TIME FOR SEQUIUM ASSET SEQUIUM ASSET SOLUTIONS, LLC, a SOLUTIONS, LLC TO RESPOND TO foreign limited-liability company,, COMPLAINT [ECF No. 1] 14 Defendants. (First Request)

16 Pursuant to Local Rules 6-1 and 7-1, Plaintiff Deborah Fowler (“Plaintiff”), and Defendant Sequium Asset Solutions, LLC (“Sequium”), by and through their respective attorneys of record, stipulate as follows: 19 STIPULATION 20 1. Plaintiff filed her Complaint on November 13, 2019 [ECF No. 1].

21 2. Sequium was served with the summons and complaint on December 17, 2019.

22 3. Sequium just retained counsel on January 6, 2020 and a short extension is necessary to allow Sequium’s counsel to obtain the file and investigate the allegations in the Complaint before responding.

25 4. Allowing an extension will also allow the parties to conduct early resolution discussions.

27 5. Plaintiff has no objection to the extension.

1 6. Therefore, the parties agree that Sequium’s response to the Complaint is now || due on or before January 28, 2020.

4 DATED: January 7, 2020. DATED: January 7, 2020, || GORDON REES SCULLY COGBURN LAW MANSUKHANI, LLP /s/ Robert S. Larsen /s/ Erik W. Fox TY Robert S. Larsen, Esq. Erik W. Fox, Esq.

8 || Nevada Bar No. 7785 Nevada Bar No. 8804 Wing Yan Wong, Esq. James S. Cogburn, Esq.

9 || Nevada Bar No. 13622 Nevada Bar No. 8409 300 So. 4" Street, Suite 1550 2580 St. Rose Parkway, Suite 330 || Las Vegas, NV 89101 Henderson, Nevada 89074 Attorneys for Defendant Attorneys for Plaintiff Deborah Fowler 11 Sequium Asset Solutions, LLC ‘Bo

13 ORDER = = 7 14 IT IS SO ORDERED ace = ~ men DANIEL J. ALBRESTS 17 UNITED STATES MAGISTRATE JUDGE DATED: January 8, 2020