Wood v. I.Q. Data International, Inc.

1 ROBERT S. LARSEN, ESQ.

Nevada Bar No. 7785 WING YAN WONG, ESQ.

Nevada Bar No. 13622 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] 6 [email protected] Attorneys for I. Q. Data International, Inc. UNITED STATES DISTRICT COURT DISTRICT OF NEVADA Tai Wood, ) Case No.: 2:19-cv-02040-APG-NJK 11 ) Plaintiffs, ) STIPULATION AND ORDER TO 12 ) EXTEND TIME FOR I.Q. DATA v. ) INTERNATIONAL, INC. TO 13 ) RESPOND TO COMPLAINT [ECF I. Q. Data International, Inc., ) NO. 1] 14 ) Defendants. ) (THIRD REQUEST) 15 )

17 Pursuant to Local Rules 6-1 and 7-1, Plaintiff Tai Wood (“Plaintiff”) and Defendant I.Q.

18 Data International, Inc. (“I.Q. Data”), by and through their respective attorneys of record, stipulate as follows: 20 STIPULATION 21 1. Plaintiff filed the Complaint on November 25, 2019. See ECF No. 1.

22 2. I.Q. Data was served with the Summons and Complaint on November 27, 2019.

23 3. I.Q. Data and Plaintiff have been exploring early resolution. To that end, the Court previously granted I.Q. Data two extensions to respond to the Complaint by January 31, 2020. ECF Nos. 8, 10.

26 4. At this time, Plaintiff anticipates filing an amended complaint to include additional allegation(s) and claim(s).

1 || Plaintiff and I.Q. Data agree that I.Q. Data will not need to file a response to the current || operative Complaint.

3 6. Plaintiff will file his Amended Complaint by February 14, 2020.

4 7. 1.Q. Data will have three (3) weeks thereafter to file its response to the Amended || Complaint.

6 8. In the event Plaintiff does not file his Amended Complaint, the parties agree that || LQ. Data’s response to the Complaint will be due on or before February 21, 2020.

8 9. This request for an extension is made in good faith and not for purposes of delay || but to help resolve any and all potential claims Plaintiff may assert in this case.

4 11 DATED: January 31, 2020. DATED: January 31, 2020.

3 GORDON REES SCULLY MANSUKHANI, KIND LAW || LLP \4 . . gee /s/ Wing Yan Wong /s/ Michael Kind x 15 || Robert S. Larsen, Esq. Michael Kind, Esq.

Nevada Bar No. 7785 Nevada Bar No. 13903 || Wing Yan Wong, Esq. 8860 S. Maryland Parkway, Suite 106 = Nevada Bar No. 13622 Las Vegas, NV 89123 & 17 ||300 So. 4" Street, Suite 1550 Las Vegas, NV 89101 Attorney for Tai Wood Attorneys for I.Q. Data International, Inc. ORDER IT IS SO ORDERED.

A 25 UNITED STAT AGISTRATE JUDGE 26 DATED: February 3, 2020