United States District Court, D. Nevada
A. RABBAT, ESQ. Nevada Bar No. 12633 TESS E. JOHNSON, ESQ.
Nevada Bar No. 13511 ENENSTEIN RIBAKOFF
LAVIÑA&PHAM Attorneys for Defendant Phillipe Rouas
William Soto Plaintiff in Pro Se
McClane Jackson Lewis P.C. Attorneys for Defendant Aria
Resort & Casino, LLC, Yong Hoon Lee, Jerald Hedrick,
Robert Fishbourne, and Todd Owen
J. Breeden Breeden & Associates, PLLC Attorneys for
DEFENDANT PHILLIPPE ROUAS'S EX PARTE MOTION FOR
ENLARGEMENT OF TIME TO MOVE, ANSWER, OR OTHERWISE RESPOND TO
PLAINTIFF'S  FIRST AMENDED COMPLAINT
PHILIPPE ROUAS (“Rouas”), by and through his
counsel, the law firm Enenstein Ribakoff LaViña &
Pham, hereby submits this Ex Parte Motion for Enlargement of
Time to Move, Answer or Otherwise Respond to Plaintiff
WILLIAM SOTO's (“Plaintiff”) First Amended
Complaint. (ECF No. 44).
Motion is made and based upon the memorandum of points and
authorities and exhibits attached hereto, all pleadings,
declarations, affidavits, and other evidence on file in this
action, and upon such oral argument and/or documentary
evidence as may be presented at the hearing on this motion.
OF ROBERT A. RABBAT, ESQ., PURSUANT TO LR 7-5(b) IN SUPPORT
OF THE EX PARTE MOTION FOR ENLARGEMENT OF TIME
Robert A. Rabbat, Esq., declare and say:
1. I am
an attorney licensed to practice law in all courts in the
State of Nevada. I am a partner of the law firm Enenstein
Ribakoff LaVina & Pham, counsel of record for Phillipe
Rouas in this action. I have personal knowledge of all facts
stated herein unless specifically stated upon information and
belief. I am over the age of 18 and I am competent to testify
submit this declaration pursuant to Local Rule 7-5(b) and in
support of Mr. Rouas' ex-parte motion for enlargement of
time to file a motion, answer, or other response to
Plaintiff's First Amended Complaint filed on May 23,
2016. (ECF No. 44).
was retained to represent Mr. Rouas today, December 12, 2016.
Ruoas is currently living outside of the United States.
Plaintiff's First Amended Complaint was served by
publication in the Nevada Legal News from October 24, 2016 to
November 21, 2016. (ECF No. 85).
Ruoas only very recently learned of the service of
Plaintiff's First ...