Nevada Corporate Headquarters v. Hill

1 ROBERT S. LARSEN, ESQ.

Nevada Bar No. 7785 DIONE C. WRENN ESQ.

Nevada Bar No. 13285 GORDON REES SCULLY MANSUKHANI, LLP South Fourth Street, Suite 1550 Las Vegas, Nevada 89101 Telephone: (702) 577-9300 Direct: (702) 577-9304 Facsimile: (702) 255-2858 E-Mail: [email protected] [email protected] Attorneys for Alfonso Valle UNITED STATES DISTRICT COURT DISTRICT OF NEVADA NEVADA CORPORATE HEADQUARTERS, A Case No.: 2:20-cv-01721-RFB-VCF Nevada Corporation, STIPULATION AND ORDER TO 12 Plaintiff, EXTEND DEADLINE FOR COUNTERCLAIMANT ALFONSO vs. VALLE TO RESPOND TO DEFENDANT/ JANETTE M. HILL; JOHN DOE; ATTORNEY COUNTERCLAIMANT’S DOE; and DOES 1 through X and ROE Corporations COUNTERCLAIM or Business Entities I through X, inclusive, 16 Defendants.

19 JANETTE M. HILL, individually, 20 Counterclaimant, vs. NEVADA CORPORATE HEADQUARTERS, A Nevada Corporation; JASON WILLIAMS, individually; ALFONSO VALLE, individually, 24 Counterdefendants.

IT IS HEREBY STIPULATED by and between Counter-Defendant Alfonso Valle (“Valle”), through his counsel of record, Gordon Rees Scully Mansukhani, LLP, and Defendant/Counterclaimant Janette M. Hill (“Counterclaimant”), through their counsel of record, Lagomarsino Law, that Counter-Defendant shall have a fourteen-day extension of time to submit his response to Counterclaimant’s Counterclaim. This stipulation is submitted and based upon the following: 4 1. On February 5, 2020, Plaintiff/Counter-Defendant Nevada Corporate Headquarters (“NCH”) filed a Complaint in the Eighth Judicial District Court, Clark County, Nevada, case no. A-20-809853-C, against Defendant/Counterclaimant Hill. On July 1, 2020, NCH filed an Amended Complaint.

8 2. On August 17, 2020, Counterclaimant filed a Counterclaim against Counter- Defendants Valle, NCH, and Jason Williams (“Williams”) (collectively, Valle, NCH, and Williams are referred to as “Counter-Defendants”).

11 3. On September 15, 2020, Valle notified Counterclaimant that service of the Counterclaim was deficient, and agreed to accept service of the Counterclaim by electronic means. Valle further agreed to file a response to the Counterclaim on October 6, 2020 14 4. On September 16, 2020, NCH filed a Notice of Removal to the United States District Court, District of Nevada. See ECF No. 1.

16 5. Currently pending before this Court is NCH and Williams’ Stipulation to Extend Deadline for Plaintiff and Counter-Defendants to Respond to Defendant/Counterclaimant’s Counterclaim. See ECF No. 6. Therein, NCH and Williams seek an extension to file a response to the Counterclaim because Defendant/Counterclaimant intends to file an Amended Counterclaim on or before October 5, 2020 in order to address administrative remedies and the inclusion of individually named defendants as parties in alleged Title VII violations. Id. 22 6. In light of the forthcoming First Amended Counterclaim, Defendant/Counterclaimant and Valle have agreed that Valle shall forego filing a response to the Counterclaim and have fourteen (14) days from the filing date of the First Amended Counterclaim to file a response.

26 7. This is the first request for an extension of time for Valle to file a response to Defendant/Counterclaimant’s Counterclaim.

1 8. This request is made in good faith and not for the purpose of delay.

2 Dated: September 24, 2020 Dated: September 24, 2020 GORDON REES SCULLY LAGOMARSINO LAW || MANSUKHANI, LLP /s/ Dione C. Wrenn /s/ Andre M. Lagomarsino ROBERT S. LARSEN, ESQ. Andre M. Lagomarsino, Esq.

Nevada State Bar No. 7785 Nevada State Bar No. 6711 g DIONE C. WRENN, ESQ. 3005 W. Horizon Ridge Pkwy., #241 Nevada State Bar No. 13285 Las Vegas, NV 89052 |} 300 South 4 Street, Suite 1550 Attorney for Defendant/Counterclaimant, Las Vegas, Nevada 89101 Janette M. Hill 10 Attorneys for Counter-Defendant, 4 ll Alfonso Valle

\4 ORDER as IT IS SO ORDERED = 16 : ee & 17 i a ae i = comet had pa ee = □ 18 UNITED STATES MAGISTRATE JUDGE 19 DATED: 9-25-2020