`
`ROBERT S. LARSEN, ESQ.
`Nevada Bar No. 7785
`GORDON & REES LLP
`300 South Fourth Street, Suite 1550
`Las Vegas, Nevada 89101
`Telephone: (702) 577-9300
`Facsimile: (702) 255-2858
`E-Mail: rlarsen@gordonrees.com
`Attorneys for Retrieval-Masters
`Creditors Bureau, Inc.
`
`UNITED STATES DISTRICT COURT
`DISTRICT OF NEVADA
`
`JORGE HERNANDEZ,
`Plaintiff,
`
`vs.
`RETRIEVAL-MASTERS CREDITORS BUREAU,
`INC., a foreign corporation doing business as
`AMERICAN MEDICAL COLLECTION AGENCY
` Defendants.
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Case No.: 2:16-CV-02591-JCM-VCF
`
`STIPULATION AND ORDER TO
`EXTEND TIME TO FILE
`ANSWER TO COMPLAINT
`[ECF NO. 1]
`FIRST REQUEST
`
`Pursuant to Local Rules 6-1 and 7-1, Plaintiff Jorge Hernandez (“Plaintiff”), and
`Defendant Retrieval-Masters Creditors Bureau, Inc. (“RCMB”), by and through their respective
`attorneys of record, stipulate as follows:
`STIPULATION
`Plaintiff filed his Complaint on November 8, 2016 [ECF No. 1].
`1.
`RMCB recently retained counsel and a short extension is necessary to allow
`2.
`RMCB’s counsel to obtain the file and investigate the allegations in the Complaint before
`responding.
`Plaintiff and RMCB also anticipate in engaging in settlement discussions on this
`3.
`case and wish to extend the deadline for RMCB to respond to the Complaint until December 16,
`2016. This will allow the parties to continue settlement discussions without incurring additional
`fees and expenses.
`/ / /
`
`-1-
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`300 South Fourth Street
`Gordon & Rees LLP
`
`Las Vegas, NV 89101
`
`Suite 1550
`
`
`
`Case 2:16-cv-02591-JCM-VCF Document 5 Filed 11/18/16 Page 2 of 2
`
`RMCB requests additional time to file a response to the Complaint and Plaintiff
`4.
`does not object to the request.
`5.
`Therefore, the parties agree that RMCB’s response to the Complaint is now due
`on or before December 16, 2016.
`
`DATED: November __, 2016.
`GORDON & REES LLP
`/s/ Robert S. Larsen
`ROBERT S. LARSEN, ESQ.
`Nevada Bar No. 7785
`300 South Fourth Street, Suite 1550
`Las Vegas, Nevada 89101
`Attorneys for Retrieval-Masters Creditors
`Bureau, Inc.
`
`DATED: November __, 2016.
`
`/s/ Mitchell D. Gliner
`MITCHELL D. GLINER, ESQ.
`Nevada Bar No. 3419
`3017 W. Charleston Blvd., #95
`Las Vegas, NV 89102
`Attorney for Plaintiff Jorge Hernandez
`
`ORDER
`IT IS SO ORDERED.
`
`UNITED STATES
`DATED:
`
` JUDGE
`
`-2-
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`300 South Fourth Street
`Gordon & Rees LLP
`
`Las Vegas, NV 89101
`
`Suite 1550
`
`1128555/30498295v.1
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
