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United States of America for the Use and Benefit of Wells Cargo, Inc. v. Alpha Energy and Electric, Inc.
Michael D. Stanger 1 || Nevada Bar No. 8272 STRONG & HANNI, P.C. 2 || 102 South 200 East, Suite 800 3 Salt Lake City, Utah 84111 Telephone: (801) 532-7080 4 || Facsimile: (801) 596-1508 Email: mstanger@ strongandhanni.com Kent F. Larsen, Esq. 6 || Nevada Bar No. 3463 5 SMITH LARSEN & WIXOM 1935 Village Center Circle 8 Las Vegas, Nevada 89134 Tel: (702) 252-5002 9 || Fax: (702) 252-5006 Email: kf1@slwlaw.com 10 || Attorneys for Third Party Defendant 4 Southwestern Construction, Inc.
D UNITED STATES DISTRICT COURT
DISTRICT OF NEVADA
[13] g S UNITED STATES OF AMERICA FOR CASE NO: 2:18-cv-01182-JCM-CWH ci 14 || THE USE AND BENEFIT OF WELLS
CARGO, INC., STIPULATION TO EXTEND TIME
a FOR REPLY MEMORANDUM IN Plaintitt, SUPPORT OF SOUTHWESTERN’S y MOTION FOR SUMMARY
C47 JUDGMENT
ALPHA ENERGY AND ELECTRIC, INC., .
=&4© 18 || a Missouri Corporation, and American (First Request) = Contractors Indemnity Company, a 19 |) California corporation, 20 Defendants. >, || ALPHA ENERGY AND ELECTRIC, INC., a Missouri Corporation, 72 Third-Party Plaintiff,
[23] v.
[24] NORTHCON, INC., an Idaho Corporation; 25 || SOUTHWESTERN CONSTRUCTION, INC., a Utah Corporation; DOES | through 26 10; and ROE Corporations 1 through 10, 27 Third-Party Defendants.
[28] Plaintiffs and Defendants, by and through their respective council of record an 5 pursuant to LR JA 6-1, hereby stipulate that Southwestern Construction, Inc. (“Southwestern’ 3 || shall have an extension to and including June 7, 2022, given the current due date of May 3 4 ||2022, to file its Reply Memorandum in Support of Southwestern’s Motion for Summat 5 Judgment. In support of this stipulation, the parties state as follows: 1. Southwestern’s Reply Memorandum is currently due on May 31, 2022. 8 2. Southwestern seeks an extension of time to and including June 7, 2022, to serve i 9 Reply Memorandum. 10 3. This is the first stipulation for extension of time to file any reply memoranda. i 4. This extension is requested to accommodate the litigation schedule of Mr. Stange
[12] Southwestern’s lead counsel, as well as some Covid issues with Mr. Stanger’s sta
[13] 4 and co-workers, and time spent assisting Mr. Stanger’s wife who had surgery. %
< 5. The parties agree that Southwestern’s Reply Memorandum shall be due on or □□□□□
BB © fs Bas 16 June 7, 2022.
[17] 5 ~ 6. The parties move the Court to enter an Order consistent with this stipulation. to
[18] DATED this 31‘ day of May, 2022. /s/ Michael D. Stanger 19 Michael D. Stanger 50 Kent F. Larsen, Esq. Attorneys for Third-Party Defendant 21 Southwestern Construction, Inc. 22 DATED this 31‘ day of May, 2022. /s/ Stephen J. Moore (Signed by Michael D. Stanger with 23 g y permission of Stephen J. Moore) 24 Stephen J. Moore Paul K. Hentzen, Esq. 25 Jakub P. Medrala, Esq. 46 Attorneys for Defendant/Third-Party Plaintiff Alpha Energy and Electric, Inc.
[27] DATED this 31* day of May, 2022. /s/ Benjamin J. McDonnell 28 (Signed by Michael D. Stanger with
permission of Benjamin J. McDonnell) | Benjamin J. McDonnell 5 Ryan D. Yahne Donna DiMaggio 3 Brian W Boschee Attorneys for Third-Party Defendant 4 Northcon, Inc. > DATED this 31‘ day of May, 2022. /s/ Jordan F. Faux 6 (Signed by Michael D. Stanger with permission of Kurt C. Faux) 7 Kurt C. Faux, Esq. 8 Willi H. Siepmann, Esq. Jordan F. Faux, Esq. 9 Attorneys for American Contractors Indemnity Company
[12] IT IS SO ORDERED:
[14] % is || Pete CO. teller ~ ||UNIFED STATES DISTRICT JUDGE 16 “
DATED: _ May 31, 2022
[28] CERTIFICATE OF SERVICE > hereby certify that on this 31‘ day of May, 2022, a true and correct copy of the foregoin
STIPULATION TO EXTEND TIME FOR REPLY MEMORANDUM IN SUPPORT O
3 || SOUTHWESTERN’S MOTION FOR SUMMARY JUDGMENT was electronically v ECF notification upon all counsel of record. 5 /s/ Michael D, Stanger
[12] mo 13
|4
[5] moO B .
[17] BESS 1s
