Campagna et al v. Talk Fusion, Inc. et al

Middle District of Florida, flmd-8:2016-cv-00796

ORDER Granting {{20}} Stipulation. Joint Status Report due by 2/25/2015. Signed by Judge Richard F. Boulware, II on 2/23/15. (Copies have been distributed pursuant to the NEF - TR) [Transferred from nvd on 4/1/2016.]

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PageID 279 G. MARK ALBRIGHT, ESQ. Nevada Bar No. 001394 ALBRIGHT, STODDARD, WARNICK & ALBRIGHT 801 South Rancho Drive, Suite D - 4 Las Vegas, Nevada 89106 Tel: (702) 384 - 7111 Fax: (702) 384 - 0605 gma @ albrightstoddard. com Attorneys for Defendant Talk Fusion, Inc. And Robert Reina UNITED STATES DISTRICT COURT DISTRICT OF NEVADA 2: 15 - cv - 00090 - RFB - CWH JULIE CAMPAGANA, an individual; MINH HO, an individual; and MJ RICH MEDIA, CORP ., a Nevada corporation, CASE NO. DEPT NO. Plaintiffs, STIPULATION AND ORDER TO EXTEND TIME TO FILE JOINT STATUS REPORT vs. (First Request) LAW OFFICES ALBRIGHT, STODDARD, WARNICK S ALBRIGHT A PROFESSIONAL CORPORATION QUAL PARK, SUITE D SOI SOUTH RANCHO DRIVE LAS VEGAS, NEVADA 89106 TALK FUSION, INC ., a Florida corporation; ROBERT REINA, an individual; and DOES 1 through 50, inclusive, Defendants. Plaintiffs, Julie Campagna, an individual; Minh Ho, an individual; and MJ Rich Media Corp ., a Nevada corporation (hereinafter " Plaintiffs"), by and through their undersigned counsel Michael D Rawlins, Esq. and Bradley S. Slighting Esq. of Durham Jones & Pinegar, and Talk Fusion, Inc ., a Florida corporation; and Robert Reina, an individual (hereinafter " Defendants"), by and through their undersigned counsel G. Mark Albright, Esq. of Albright, Stoddard, Warnick & Albright, hereby stipulate and consent to an Order of this Court consistent with the following: 1. On or about January 16, 2015, Defendant Talk Fusion, Inc. filed a Notice of Removal in the above entitled action based on diversity. 2711 2. On January 16, 2015, the Court ordered that counsel file a Joint Status Report by 28 | February 18, 2015. Casę 8: 16 - cv - 00796 - CEH - JSS Document 29 Filed 02 / 23 / 15 Page 2 of 2 Pageld 280 3. Plaintiffs and Defendants hereby stipulate and seek Court confirmation by Order, pursuant to LR 7 - 1, for an extension of time through and including February 25, 2015 for filing of the Joint Status Report in this case. 4. Nothing herein shall be construed as a waiver of the Defendants ' rights to contest jurisdiction and venue, and to compel arbitration. 5. The parties further stipulate that this request for extension is made in good faith, for good cause and not merely for the purpose of delay. STIPULATED AND AGREED DATED this 78 % day of February, 2015 DATED this _ 17 day of February, 2015 ALBRIGHT, STODDARD, WARNICK & DURHAM JONES & PINEGAR ALBRIGHT ALBRIGHT / M w Bladet y t By Dredlen S. Past Pigating LAW OFACES ALBRIGHT, STODDARD, WARNICK S ALBRIGHT A PROFESSIONAL CORPORATION QUAL PARK, SUITE D - 4 S01 SOUTH RANCHO DRIVE LAS VEGAS, NEVADA 9106 By G. Mark Albright Esq. Nevada Bar No. 001394 801 South Rancho Drive, Suite D - 4 Las Vegas, NV 89106 Attorneys for Defendants Michael D. Rawlins, Esq. Nevada Bar No. 5467 Bradley S. Slighting, Esq. Nevada Bar No. 10225 10785 West Twain Avenue, Suite 200 Las Vegas, Nevada 89135 Attorneys for Plaintiffs ORDER IT IS SO ORDERED: B OD RICHARD F. BOULWARE, II United States District Judge DATED this 23rd day of February, 2015. - 2